JAMES v. RPS HOLDINGS, LLC, 1:20-cv-00134

Plaintiff Siobhan James sued PRS Partners, LLC alleging FLSA and NCWHA wage claims (misclassification as an independent contractor) and common-law tort claims based on an alleged assault by a manager at Capital Cabaret in Morrisville.
PRS moved to compel arbitration of all claims under an arbitration agreement James signed on August 4, 2015 with “Cap Cab”/“Capital Cabaret” that waived class/collective actions, invoked JAMS rules, and specified arbitration in Charlotte (within 25 miles of the last place of service).
James opposed, arguing she did not sign an agreement with PRS (the Agreement names “Cap Cab”), and that the Charlotte-within-25-miles clause is geographically impossible for Morrisville.
The Court examined the Agreement and public records: a Wake County assumed-name certificate shows RPS Holdings, LLC does business as Capital Cabaret; PRS did not file an assumed-name certificate in Wake County.
PRS asserted (in counsel argument) it does business as Capital Cabaret; the Court found no admissible record evidence linking PRS to the Agreement or to RPS Holdings, LLC.
The Court denied PRS’s motion to compel arbitration without prejudice, concluding PRS failed to show it was a party to the arbitration agreement and therefore could not compel arbitration; the Court declined to resolve the geographic-enforcement issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does an arbitration agreement exist between James and PRS?	James: Agreement was with “Cap Cab”/Capital Cabaret, not PRS.	PRS: It does business as Capital Cabaret (Cap Cab) and is therefore bound.	Denied — PRS failed to produce admissible evidence linking PRS to the Agreement; no showing PRS was a party.
Can a non‑signatory like PRS enforce the Agreement?	James: PRS is a non‑signatory and offers no basis to bind a non‑signatory.	PRS: Impliedly relies on d/b/a/assumed‑name to enforce arbitration.	Denied — PRS did not assert or prove applicable non‑signatory doctrines; record does not tie PRS to RPS Holdings, LLC.
Is the Agreement unenforceable because the arbitration location is geographically impossible?	James: Charlotte within 25 miles of Morrisville is impossible; clause is problematic.	PRS: Location dispute does not preclude arbitration; parties could agree to another site.	Not decided — Court declined to reach this issue after finding PRS not shown to be a party; noted geography may impede enforcement.
What burden does a movant have to compel arbitration?	James: (denies existence of agreement)	PRS: Must produce evidence of a valid arbitration agreement.	Court: Movant must produce credible admissible evidence showing an agreement; opponent must then make an unequivocal denial with supporting facts. PRS did not meet its burden.

Atlantic Marine Constr. Co. v. United States Dist. Ct., 571 U.S. 49 (2013) (forum‑selection clause concepts applied to arbitration clauses)
Granite Rock Co. v. International Bhd. of Teamsters, 561 U.S. 287 (2010) (court must conclude an express arbitration agreement exists before compelling arbitration)
Whiteside v. Teltech Corp., 940 F.2d 99 (4th Cir. 1991) (FAA provides for enforcement of arbitration agreements)
Chorley Enters., Inc. v. Dickey’s Barbecue Rests., Inc., 807 F.3d 553 (4th Cir. 2015) (motion to compel standard akin to summary judgment; proponent must produce credible evidence)
International Paper Co. v. Schwabedissen Maschinen & Anlagen GMBH, 206 F.3d 411 (4th Cir. 2000) (non‑signatories may enforce arbitration agreements in limited circumstances)
American Bankers Ins. Grp. v. Long, 453 F.3d 623 (4th Cir. 2006) (non‑signatory enforcement principles explained)
AMOCO v. AAN Real Estate, LLC, 232 N.C. App. 524 (N.C. Ct. App. 2014) (assumed‑name filing can determine standing to enforce contracts)
Phillips v. Pitt Cty. Mem. Hosp., 572 F.3d 176 (4th Cir. 2009) (courts may take judicial notice of public records)