Jones v. Carrols, L.L.C.
2017 Ohio 7150
| Ohio Ct. App. | 2017Background
- Erick Jones worked for Carrols, LLC (Burger King) from 2004 and was promoted to shift supervisor; he was terminated in December 2012.
- In July 2006 Carrols implemented a Mandatory Arbitration Policy (MAP) requiring arbitration of most employment claims; new hires signed the MAP, current employees were informed by memorandum and posters and told that reporting to work after August 1, 2006 signified agreement.
- Jones filed suit in December 2013 alleging racial and age discrimination and related tort claims. Defendants moved to compel arbitration under the MAP; Jones denied he had agreed to it and challenged its enforceability.
- The trial court originally granted the motion to compel arbitration without detailed analysis; this court reversed and remanded because the trial court failed to determine whether Jones knew about the MAP.
- On remand the trial court found Jones had knowledge of the MAP, reiterated prior (sparse) findings that the MAP was lawful and not unconscionable, and granted Defendants’ renewed motion to compel and dismissed the complaint.
- The Court of Appeals reversed and remanded again, holding the trial court’s entries lack sufficient analysis on multiple contested issues (unconscionability, public policy, enforceability, scope, waiver of jury), preventing meaningful appellate review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether MAP is procedurally or substantively unconscionable | Jones: MAP is unconscionable and invalid | Defs: MAP is lawful and not unconscionable | Trial court made findings but provided no analysis; appellate court remands for detailed findings |
| Whether MAP violates public policy (class-action waiver) | Jones: MAP is against public policy because it waives class actions | Defs: Class-action waiver is permissible under MAP | Appellate court did not decide merits; remanded for trial court analysis |
| Whether MAP created a valid, enforceable arbitration agreement | Jones: No valid mutual assent/binding agreement for current employees | Defs: Company gave reasonable notice; Jones assented by reporting to work | Appellate court found insufficient trial-court analysis; remanded for further findings |
| Whether Jones’ claims fall within MAP scope and whether jury-trial right was waived | Jones: Claims fall outside MAP; he never waived constitutional jury right | Defs: Claims are arbitrable; MAP includes jury-trial waiver | Appellate court concluded trial entries lack necessary explanation on scope and waiver; remanded |
Key Cases Cited
- Murphy v. Reynoldsburg, 65 Ohio St.3d 356 (1992) (court’s procedural obligations when considering evidence and making findings)