Blackmon v. Family Dollar Stores of New York, Inc.

Background

Henry Blackmon sued Family Dollar Stores of New York, Inc. and Family Dollar, LLC, which the opinion calls “Family Dollar,” along with unidentified defendants. He alleged discrimination, retaliation, failure to provide reasonable accommodation, and hostile work environment based on disability under the Americans with Disabilities Act, the New York State Human Rights Law, and the New York City Human Rights Law. He also alleged religious discrimination under the two New York statutes.

Blackmon alleged that he has Type 2 diabetes, diabetic neuropathy, a heart condition, anxiety, and a back disability. He said Family Dollar denied or failed to address requests for work accommodations, required him to work under conditions that affected his health, removed him from the work schedule during an investigation, later required him to work without accommodations, and ultimately denied his accommodation request. He also alleged that a new store manager favored Muslim employees over non-Muslim employees and that Family Dollar did not respond adequately to his complaints. The opinion states that some details in the complaint were unclear, including whether certain accommodation requests were affirmatively denied or simply left unanswered.

Motion and legal standard

Family Dollar moved to compel arbitration of Blackmon’s employment-discrimination claims and to dismiss the lawsuit. The court applied the Federal Arbitration Act, a federal law that generally enforces written agreements to arbitrate, together with state contract-law principles governing whether an arbitration agreement was formed.

The court first considered whether an arbitration agreement existed. Family Dollar submitted a Mutual Agreement to Arbitrate Claims requiring arbitration of claims arising from or related to Blackmon’s employment, including claims involving working conditions, retaliation, and discrimination based on race, religion, disability, or medical condition. The agreement also specifically included employment-related claims under the Americans with Disabilities Act.

Blackmon stated that he saw the agreement during an in-store application process but did not understand its scope and told the store manager that he could not agree to something he did not understand. He also disputed Family Dollar’s description of the application process. The court nevertheless concluded that, even if one alleged signing were disregarded, Blackmon had effectively conceded that he entered into the agreement on at least two other occasions. The court also ruled that a person’s failure to read or understand a contract does not, by itself, make the contract unenforceable.

Ruling

The court found that a valid arbitration agreement existed. It then determined that the agreement covered all of the claims in Blackmon’s complaint because the agreement expressly included employment-related discrimination and retaliation claims based on disability, race, religion, or medical condition, including claims under the Americans with Disabilities Act.

The court granted Family Dollar’s motion. It directed the clerk to terminate the motion and stayed the case. The parties were ordered to file a status update within 48 hours after arbitration ends. The opinion does not state that the court separately dismissed the action in its concluding order.