Haight v. Cheap Escape Co.
2013 Ohio 182
Ohio Ct. App.2013Background
- Haight and Pence signed a non-compete agreement with an arbitration clause as part of JB Dollar’s employment agreement.
- Appellees’ February 6, 2012 wage/commissions, breach of contract, and quantum meruit claims were filed in state court.
- JB Dollar moved to stay proceedings and compel arbitration under RC 2711.02/2711.03, asserting the arbitration clause covers wage-related claims.
- The trial court overruled, holding the arbitration clause only covered non-compete/non-disclosure issues and wage claims were outside its scope.
- JB Dollar appealed, arguing the wage claims fall within the arbitration clause and that the court erred by not granting a stay and compel arbitration; the court reviews arbitrability de novo and favors arbitration where applicable.
- The court ultimately held the arbitration clause applies only to non-compete/non-disclosure issues, wage claims are outside its scope, and affirmed the trial court’s decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether wage claims fall within the arbitration clause | Haight argues the clause covers only non-compete/non-disclosure. | JB Dollar argues the arbitration clause is broad and applies to disputes arising from the agreement, including wage claims. | No; wage claims are outside the arbitration scope. |
Key Cases Cited
- Schaeffer v. All State Ins. Co., 63 Ohio St.3d 708 (Ohio 1992) (arbitration policy favors expedient resolution of disputes)
- McManus v. Eicher, 2003-Ohio-6669 (2d Dist. Greene No. 2003-CA-30) (arbitrability is a question of law, reviewed de novo)
- St. Mary’s v. Auglaize Cty. Bd. of Commrs., 115 Ohio St.3d 387 (2007-Ohio-5026) (contract interpretation is a matter of law; ambiguity resolved in favor of non-drafting party)
- Alexander v. Buckeye Pipe Line Co., 53 Ohio St.2d 241 (1978) (clear contract language controls; intent inferred from writing)
- Westfield Ins. Co. v. Galatis, 100 Ohio St.3d 216 (2003-Ohio-5849) (unambiguous terms; strict construction if ambiguity exists)
- Davis v. Loopco Industries, Inc., 66 Ohio St.3d 64 (1993) (contract interpretation governed by law; ambiguity resolved in favor of weaker party)