eNotes: Liability – October 2023 – Washington, D.C.

SIGNIFICANT CASE SUMMARIES

Washington, DC Case Summary

Gonzales v. GrubHub Holdings, Inc.
U.S. District Court for the District of Columbia
No. 23-cv-1650

Decided: September 14, 2023

In wage dispute, an employee’s agreement to a digital employment contract was sufficient to make an arbitration provision enforceable.

Background

From 2018 through 2021, Plaintiff performed deliveries for Defendant through use of its digital platform under a contract. That agreement, available through its digital platforms, contained an arbitration clause. Plaintiff alleged that the Defendant expanded the geographic region of his performance, and failed to pay him minimum wage, overtime and regular tips.

Defendant removed the case to the Federal District Court before answering and, upon removal, filed a Motion compelling arbitration. The Court granted that Motion after Plaintiff effectively failed to substantively respond.

Holding

The District Court for the District of Columbia granted Defendant’s Motion to arbitrate, finding the agreement enforceable. The contract indicated that the relationship between the parties was not one of employer-employee, but was rather one of principal and contractor. The arbitration provision contained an opt-out provision that required individuals who entered the agreement to email Defendant within thirty days of accepting the agreement to opt-out of the arbitration provision. The arbitration provision was enforceable under the standard provisions of the Federal Arbitration Act, with the Court specifically noting that said Act did not provide any discretion to the Courts and mandated the enforcement of valid arbitration provisions. In this matter, Plaintiff’s response to the Motion did not dispute the enforceability or validity of the agreement, so his dispute was relegated to arbitration.

Questions about this case can be directed to Joseph Mooradian at (202) 318-1751 or jmooradian@tthlaw.com.