Jones v. U-Haul Co., 16 F. Supp. 3d 922

Background

Stacy Jones, long‑time U‑Haul reservation manager (hired 1999), signed two arbitration agreements: a paper UAP on Jan 12, 2007 and an electronic EDR agreement allegedly signed June 18, 2007; she continued employment until resigning in 2013.
U‑Haul’s UAP (initial) was announced for new hires but stated it would apply to existing employees who sign and that continuing employment constitutes assent; the later EDR expressly applied to all employees.
Jones sued asserting Title VII, ADEA, Ohio FEPA, and various common‑law claims, and challenged the arbitration agreements as unconscionable, procured by duress/undue influence, lacking consideration, and as waiving jury rights unknowingly.
Defendants moved to compel arbitration under the Federal Arbitration Act and sought dismissal or stay; they submitted affidavits and the arbitration documents, plus evidence of electronic signature procedures.
The district court applied Ohio contract law (with FAA federal policy favoring arbitration) and resolved disputes in defendant’s favor: it found both agreements valid, Jones had assented (including by continued employment), the electronic signature was authentic, and the claims fall within the agreements’ scope.
The court granted the motion to compel arbitration and dismissed the case without prejudice, permitting defendants to move for fees/costs for preparing the motion.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Jones agreed to arbitrate (formation/authenticity)	Jones says UAP didn’t apply to her as a non‑new employee and she doesn’t recall/authenticate the electronic EDR signature	Jones signed the UAP and electronically signed EDR; HR system and affidavit establish authenticity; continued employment ratified EDR	Court: Jones validly assented to both; electronic signature authentic; continued employment binds her
Whether agreements are unconscionable / contracts of adhesion	Agreements are adhesion, procedurally & substantively unconscionable, signed under pressure	Agreements were conspicuous, encouraged counsel, and ordinary contractual principles apply; employer’s condition of continued employment is permissible	Court: No procedural unconscionability; not unenforceable as adhesion contracts
Duress / undue influence and sufficiency of consideration	Jones was pressured/forced to sign to keep job; no new consideration was given	Signing as condition of continued at‑will employment and mutual promise to arbitrate provides consideration	Court: No evidence of duress/undue influence; continued employment and mutual arbitration promise constitute sufficient consideration
Arbitrability / scope and arbitrability of statutory claims	Individual‑capacity claims and statutory claims should be litigated in court; FAA unconstitutional or violates jury rights	Agreements expressly cover employment and individual actors; ADEA and Title VII claims arbitrable; FAA is constitutional/preemptive	Court: Agreements cover all claims including against individual employees; ADEA/Title VII arbitrable; constitutional challenge waived procedurally and rejected

Key Cases Cited

Gilmer v. Interstate/Johnson Lane Corp., 500 U.S. 20 (that statutory employment claims may be subject to arbitration)
Moses H. Cone Mem'l Hosp. v. Mercury Constr. Corp., 460 U.S. 1 (federal policy favors arbitration and doubts resolved for arbitration)
Howsam v. Dean Witter Reynolds, Inc., 537 U.S. 79 (gateway arbitrability questions for courts to decide)
Stout v. J.D. Byrider, 228 F.3d 709 (6th Cir.) (four‑part test for motions to compel arbitration)
E.E.O.C. v. Waffle House, Inc., 534 U.S. 279 (courts should not override clear intent of parties even favoring arbitration)
Great Earth Cos. v. Simons, 288 F.3d 878 (6th Cir.) (state contract law governs general defenses to arbitration clauses)