Sharon Owen v. Bristol Care, Inc., 702 F.3d 1050

Bristol Care signed a Mandatory Arbitration Agreement (MAA) with Owen at hiring, covering wage and FLSA claims and providing for binding arbitration of disputes.
The MAA includes a waiver prohibiting arbitration of claims on behalf of a class (class waiver), but allows agency complaints (EEOC, etc.).
Owen filed a September 2011 FLSA action alleging misclassification and overtime violations on behalf of herself and others, seeking class certification.
Bristol Care sought to stay proceedings and compel arbitration under the FAA, but the district court denied, deeming the MAA invalid due to the class waiver.
The district court relied on D.R. Horton (NLRB) and related authority to conclude class waivers are invalid in FLSA cases.
This court reverses, holding the MAA’s class waiver enforceable and directs the district court to compel arbitration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are class waivers in arbitrations of FLSA claims enforceable?	Owen argues FLSA implies a right to class actions that overrides FAA.	Bristol Care argues no contrary command; FAA preempts any such override.	Class waiver enforceable; no contrary command in FLSA.
Is D.R. Horton controlling for enforceability of class waivers in this context?	Owen relies on D.R. Horton to invalidate the waiver.	Bristol Care contends D.R. Horton is not controlling here.	D.R. Horton is not controlling; court declines to follow it and aligns with other circuits.

Gilmer v. Interstate/Johnson Lane Corp., 500 U.S. 20 (1991) (arbitration enforceability in employment disputes)
Concepcion v. AT&T Mobility LLC, 563 U.S. 333 (2011) (pro-arbitration in consumer contracts upheld)
CompuCredit Corp. v. Greenwood, 132 S. Ct. 665 (2012) (liberal federal policy favoring arbitration agreements)
Carter v. Countrywide Credit Indus., Inc., 362 F.3d 294 (5th Cir. 2004) (arbitration waivers in consumer/finance contexts)