Peter Anderson, Jr. v. Charter Comm'ns, Inc., 20-5894

Background

Anderson worked 18 years for Charter (Spectrum) and was fired in 2018; he sued in Kentucky state court and Charter removed the case to federal court.
In 2017 Charter emailed employees a “Solution Channel” arbitration program with a 30‑day opt‑out; Anderson did not opt out and the agreement covered disputes “arising out of or relating to” his termination, but carved out “[c]laims older than the statute of limitations applicable to such claims.”
The agreement expressly delegated questions of arbitrability and arbitrability‑related issues (including unconscionability/enforceability) to the arbitrator.
The district court compelled arbitration and dismissed Anderson’s suit with prejudice; Anderson appealed, arguing lack of coverage, unconscionability, and inadequate consideration.
The Sixth Circuit affirmed the order compelling arbitration but held the district court should have stayed the action pending arbitration rather than dismissing it.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Coverage: Does the arbitration agreement cover Anderson’s claims given the statute‑of‑limitations carveout?	The carveout excludes claims that became time‑barred while the case was pending, so claims are not covered.	The agreement unambiguously delegates arbitrability/coverage questions to the arbitrator.	Arbitrator decides coverage; court affirmed that the contract delegates this question.
Enforceability/Unconscionability: Who decides whether the arbitration agreement is unconscionable?	Anderson says the agreement is unconscionable (unequal bargaining power, coercion to accept to keep job, discovery limits).	Charter says the agreement contains a delegation clause sending enforceability challenges to the arbitrator.	Arbitrator decides unconscionability because Anderson challenged the agreement as a whole and did not specifically attack the delegation clause.
Consideration: Was Charter’s promise adequate consideration for arbitration?	Anderson contends Charter gave no new consideration (he already had employment).	Charter gave mutual consideration by waiving its right to litigate and agreeing to arbitrate disputes with Anderson.	Even if a court must decide, Kentucky law deems mutual agreement to arbitrate sufficient consideration; court finds consideration adequate.
Remedy: Should the district court have dismissed the suit or stayed it pending arbitration?	Dismissal risks statute‑of‑limitations prejudice if arbitrator finds agreement unenforceable and Anderson must refile.	Charter sought dismissal; argued efficiency and that arbitration would resolve all claims.	Reversed dismissal; remanded with instruction to stay the case pending arbitration because dismissal could prejudice Anderson and several gateway issues were left for the arbitrator.

Key Cases Cited

Henry Schein, Inc. v. Archer & White Sales, Inc., 139 S. Ct. 524 (2019) (courts must enforce arbitration contracts according to their terms, including clear delegation clauses)
Rent‑A‑Ctr., W., Inc. v. Jackson, 561 U.S. 63 (2010) (delegation clause sends unconscionability challenges to arbitrator when challenge targets the agreement as a whole)
Prima Paint Corp. v. Flood & Conklin Mfg. Co., 388 U.S. 395 (1967) (general contract‑law challenges to a contract go to the arbitrator)
Buckeye Check Cashing, Inc. v. Cardegna, 546 U.S. 440 (2006) (specific challenges to an arbitration clause must be decided by a court)
First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938 (1995) (courts presumptively decide arbitrability absent clear delegation)
Sevier Cnty. Schs. Fed. Credit Union v. Branch Banking & Tr. Co., 990 F.3d 470 (6th Cir. 2021) (courts must decide whether parties actually agreed to arbitrate)
Green v. SuperShuttle Int’l, Inc., 653 F.3d 766 (8th Cir. 2011) (circuit rule allowing dismissal where entire controversy will be resolved by arbitration; discusses abuse‑of‑discretion limits on dismissal)