Bautista v. Price Water House Coopers LLP
3:24-cv-02593
| N.D. Tex. | Mar 27, 2025Background
- Robert Allen Bautista sued his employer, PricewaterhouseCoopers LLP (PWC), alleging violations of federal law including Title VII and improper tax withholding.
- Bautista had signed an arbitration agreement at the start of his employment with PWC.
- PWC filed an unopposed motion to compel arbitration and abate the federal case, which was granted by the court on November 18, 2024.
- After the order, Bautista filed several motions to reopen the case, amend his complaint, abate arbitration, and for summary judgment, arguing improper conduct by PWC and procedural unfairness in arbitration.
- PWC contended all claims (including proposed amendments) were subject to binding arbitration, and the court lacked authority to intervene while arbitration was ongoing.
- The court denied all of Bautista’s motions, affirming its prior order compelling arbitration and administratively closing the case pending outcome of arbitration.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Reopen Case After Arbitration Order | PWC is using arbitration to shield fraudulent conduct; additional evidence found | Arbitration agreement is valid; claims must go to arbitration | Motion denied; arbitration is mandatory |
| Amend Complaint | New/amended claims should be litigated or clarified in federal court | Amended claims are also subject to arbitration, so amendment is futile | Motion denied; amending would be futile |
| Court Intervention in Arbitration | Arbitration panel violated rules affecting fairness; court must intervene | Procedural challenges in arbitration not for court review before award | Motion denied; court lacks authority to intervene |
| Summary Judgment | Requested summary judgment on claims despite arbitration order | Claims subject to binding arbitration | Motion denied; summary judgment not available |
Key Cases Cited
- Dean Witter Reynolds, Inc. v. Byrd, 470 U.S. 213 (district courts must order arbitration on issues covered by a valid arbitration agreement)
- Carter v. Countrywide Credit Indus., Inc., 362 F.3d 294 (burden on party opposing arbitration to show agreement is invalid or not applicable)
- Howsam v. Dean Witter Reynolds, Inc., 537 U.S. 79 (procedural questions in arbitration are for the arbitrator, not the court)
- Gulf Guar. Life Ins. Co. v. Connecticut General Life Ins. Co., 304 F.3d 476 (federal courts have very limited pre-award intervention in arbitration)
- Smith v. Spizzirri, 601 U.S. 472 (district courts should stay, not dismiss, cases subject to arbitration to maintain supervisory role)