Famuyide v. Chipotle Mexican Grill, Inc.
- Donovan Frank
- 0:23-cv-01127
- U.S. District Court · District of Minnesota
- 10
In Famuyide v. Chipotle, Judge Frank denied arbitration, ruling the federal sexual-assault arbitration law applied because the dispute arose after enactment.
The ruling allowed Eniola Famuyide to reject arbitration under the federal sexual-assault and sexual-harassment arbitration law and denied Chipotle’s request to compel arbitration, dismiss, or stay the case.
What happened
In Famuyide v. Chipotle Mexican Grill, Inc., Eniola Famuyide alleged that another Chipotle employee sexually harassed and assaulted her while she was working there. Chipotle argued that an arbitration agreement she signed during onboarding required her claims to be arbitrated.
Famuyide argued that a federal law protecting people who bring workplace sexual-assault or sexual-harassment claims made the arbitration agreement unenforceable. Chipotle argued that the law did not apply because the alleged conduct happened before the law took effect.
Judge Donovan W. Frank denied Chipotle’s motion to compel arbitration and to dismiss or pause the case. He ruled that the dispute arose when Famuyide filed her state-court complaint in July 2022, after the law took effect, and did not decide the parties’ remaining arguments.
The detailed version
- Famuyide v. Chipotle Mexican Grill, Inc. · No. 0:23-cv-01127
- Donovan Frank
- Aug. 31, 2023
Background
Eniola Famuyide alleged that, while working at Chipotle, another employee, Lionell Bailey, repeatedly sexually harassed her and sexually assaulted her in November 2021. She alleged that Chipotle managers observed the harassment but failed to intervene, and that Chipotle did not conduct a formal investigation or provide her with resources after she reported the assault. She also alleged that Chipotle temporarily terminated her employment in February 2022, later explaining that the termination had been entered “in error” and rescinding it.
Famuyide filed claims against Chipotle in Minnesota state court on July 26, 2022. She voluntarily dismissed that case without prejudice, participated in unsuccessful mediation, and then filed this federal lawsuit asserting state-law claims related to the alleged assault and harassment. Chipotle said Famuyide had signed an arbitration agreement during onboarding on May 5, 2021. The agreement covered “any claim, dispute, and/or controversy” between Famuyide and Chipotle.
Federal sexual-assault and sexual-harassment arbitration law
Famuyide argued that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 made the arbitration agreement unenforceable. That law, signed on March 3, 2022, provides that a person alleging conduct constituting a sexual-assault dispute or sexual-harassment dispute may choose not to enforce a predispute arbitration agreement for a case related to that dispute. A statutory note states that the law applies to disputes or claims that arise or accrue on or after March 3, 2022.
The parties disagreed about when their dispute arose. Chipotle argued that it arose when the alleged assault or harassment occurred, in 2021 or earlier. Famuyide argued that the law applied to all cases filed after March 3, 2022, or, alternatively, that her dispute arose after that date.
Court’s analysis
The court interpreted “dispute” to require more than an injury or alleged wrongful conduct. It reasoned that a dispute comes into being when one side asserts a right, claim, or demand and the other side responds with disagreement. The court rejected Chipotle’s proposed rule that a dispute automatically arises on the date of the alleged assault or harassment because that would treat an injury as a dispute and assume that a conflict already existed.
The court held that the actual dispute between Famuyide and Chipotle arose when she filed her state-court complaint in July 2022. That filing occurred after March 3, 2022, so the federal law applied. The court therefore concluded that the arbitration agreement was unenforceable at Famuyide’s election.
Disposition
Judge Donovan W. Frank denied Chipotle’s motion to compel arbitration and to dismiss or, alternatively, stay the federal proceedings. Because the court concluded that the federal law applied, it did not consider the parties’ remaining arguments. The order addressed arbitration and did not decide the merits of Famuyide’s underlying claims.
Read the full 10-page opinion on CourtListener, the free public archive maintained by the Free Law Project.