History
  • No items yet
midpage
Jackson v. World Wrestling Entertainment Inc
4:23-cv-00172
N.D. Tex.
May 9, 2023
Read the full case

Background

  • WWE hosted WrestleMania 38 at AT&T Stadium on April 3, 2022; Marvin Jackson alleges hearing loss from event pyrotechnics.
  • Jackson attended using an electronic mobile ticket purchased and stored on his nephew Ashton Mott’s phone via SeatGeek; Jackson never viewed or physically possessed the ticket.
  • SeatGeek’s purchase flow and confirmation emails required purchasers to check boxes acknowledging AT&T Stadium’s Terms and an "Arbitration and Release & Waiver of Liability Agreement" (hyperlinked).
  • Accessing or accepting a transferred mobile ticket via the SeatGeek or Dallas Cowboys app required assent to the same Terms and hyperlinked Arbitration Agreement; attendees received additional "Know Before You Go" notices.
  • WWE is explicitly listed as a "Released Party" in the Arbitration Agreement; there was no real dispute that the Agreement is valid or that Jackson’s alleged injury would fall within its scope if he were covered.
  • Procedural posture: WWE moved to compel arbitration; the court granted the motion and dismissed the action with prejudice in favor of arbitration.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether a valid arbitration agreement covers the dispute Jackson contends he never agreed to or had notice of the Arbitration Agreement because Mott purchased and held the ticket WWE contends the Arbitration Agreement is valid and applies to attendees, and WWE is a released party Agreement is valid and applicable if attendee is bound; court found Agreement valid
Whether Mott’s assent binds non‑signatory Jackson Jackson argues lack of personal assent and notice means he cannot be bound WWE argues Mott acted as Jackson’s agent and Jackson, by using the ticket, is charged with notice and bound Mott acted as Jackson’s agent; Jackson is charged with notice and bound by the Arbitration Agreement
Whether Jackson’s claims fall within the Arbitration Agreement’s scope Jackson argues his injuries should be litigated in court WWE argues the alleged injuries fall within the broad waiver and arbitration scope in the ticket terms Court held Jackson’s allegations fall within the Arbitration Agreement’s scope; compelled arbitration and dismissed case

Key Cases Cited

  • Miller v. Lykes Bros. S.S. Co., 467 F.2d 464 (5th Cir. 1972) (ticket terms bind passengers even if unread)
  • Carnival Cruise Lines, Inc. v. Shute, 499 U.S. 585 (1991) (preprinted ticket terms enforceable despite lack of negotiation)
  • Arthur Andersen LLP v. Carlisle, 556 U.S. 624 (2009) (third‑party enforcement of arbitration provisions analyzed under state contract law)
  • Newman v. Plains All Am. Pipeline, L.P., 23 F.4th 393 (5th Cir. 2022) (analysis when signatory seeks to bind non‑signatory to arbitration agreement)
  • Edwards v. DoorDash, Inc., 888 F.3d 738 (5th Cir. 2018) (two‑step FAA analysis for compelling arbitration)
  • Hofer v. Gap, Inc., 516 F. Supp. 2d 161 (D. Mass. 2007) (online purchaser can bind another traveling party via agency/assent principles)
Read the full case

Case Details

Case Name: Jackson v. World Wrestling Entertainment Inc
Court Name: District Court, N.D. Texas
Date Published: May 9, 2023
Docket Number: 4:23-cv-00172
Court Abbreviation: N.D. Tex.