122 F.4th 1314
11th Cir.2024Background
- Ariel Torres and Raphyr Lubin filed a putative class action against Starbucks, alleging deficient health-insurance (COBRA) notices under ERISA.
- Torres was employed by Starbucks and had signed an arbitration agreement; Lubin, Torres’s co-plaintiff, was not a Starbucks employee but obtained coverage through his wife’s employment at Starbucks.
- Starbucks moved to compel arbitration based on the employment agreement signed by Torres and Lubin’s wife.
- Torres agreed to arbitration; Lubin opposed, arguing he never agreed to arbitrate.
- The district court denied Starbucks’s motion to compel arbitration as to Lubin, who appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether non-signatory Lubin must arbitrate under wife's agreement | Lubin: Didn’t sign or agree to arbitrate; statutory claim | Starbucks: Wife's agreement binds spouse via contract doctrines | Not required; Lubin isn’t bound as non-signatory |
| Whether delegation clause requires arbitrator to decide arbitrability | Lubin: Not a party; ambiguity in clause | Starbucks: Delegation sends threshold issues to arbitrator | Exclusion/ambiguity prevents application to Lubin |
| Whether equitable estoppel applies to compel arbitration | Lubin: Claim based on statutory, not contractual, rights | Starbucks: Lubin seeks benefits under contract, must arbitrate | No estoppel; Lubin's rights independent of contract |
| Whether third-party beneficiary or derivative claim doctrines compel arbitration | Lubin: Not suing to enforce contract as third party or derivative | Starbucks: Lubin’s claim derivative of wife's, so subject to arbitration | Doctrines don’t apply; rights are statutory, not derivative |
Key Cases Cited
- First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938 (Courts cannot compel arbitration without an agreement to arbitrate.)
- AT&T Technologies, Inc. v. Communications Workers of America, 475 U.S. 643 (Arbitration presumption doesn’t apply to questions of contract formation.)
- Seifert v. U.S. Home Corp., 750 So. 2d 633 (Fla. 1999) (A statutory claim is not subject to arbitration absent clear agreement.)
- Mendez v. Hampton Ct. Nursing Ctr., LLC, 203 So. 3d 146 (Fla. 2016) (Third-party beneficiary doctrine cannot bind a non-signatory absent a suit to enforce the contract.)
- Bahamas Sales Assoc., LLC v. Byers, 701 F.3d 1335 (11th Cir. 2012) (Equitable estoppel applies only if non-signatory sues to enforce the contract.)