Stephens v. Charter Communications Holdings, LLC
3:17-cv-00354
W.D. Ky.Sep 26, 2017Background
- Plaintiff Charles Stephens, a former Charter (formerly Time Warner Cable) customer-service employee, alleged disability discrimination and retaliatory discharge under the Kentucky Civil Rights Act after Charter denied leave accommodation and terminated him.
- Stephens filed suit in Jefferson Circuit Court; Charter removed to federal court based on diversity jurisdiction.
- Stephens submitted a post-removal stipulation through counsel that he "will not seek a judgment or request a verdict for an amount in excess of $74,999.00" and moved to remand for lack of the $75,000 amount-in-controversy.
- Charter opposed remand and separately moved to compel arbitration under a Mutual Agreement to Arbitrate Stephens electronically signed before employment, which covers state-law employment claims and invokes the Federal Arbitration Act.
- Stephens did not respond to the motion to compel arbitration.
- The court considered (1) whether the stipulation defeated diversity jurisdiction and (2) whether the arbitration agreement was valid and covered Stephens’ claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of post-removal stipulation to defeat diversity amount-in-controversy | Stephens: stipulation that he "will not seek a judgment or request a verdict" over $74,999 shows amount in controversy is below $75,000 | Charter: post-removal stipulations are disfavored; the stipulation is not unequivocal because it does not say Stephens will not accept or enforce a judgment over $75,000 | Court: Denied remand — stipulation was less than unequivocal and did not destroy jurisdiction |
| Enforceability and remedy for arbitration agreement | Stephens: did not contest enforcement | Charter: arbitration agreement is valid, covers state-law employment claims, and arbitration should be compelled (dismissal preferred if stay not sought) | Court: Granted motion to compel arbitration; dismissed the case without prejudice (no stay requested) |
Key Cases Cited
- Rogers v. Wal-Mart Stores, Inc., 230 F.3d 868 (6th Cir. 2000) (post-removal stipulation reducing amount in controversy does not automatically require remand)
- Egan v. Premier Scales & Sys., 237 F. Supp. 2d 774 (W.D. Ky. 2002) (stipulation must be unequivocal to limit recoverable damages and warrant remand)
- Stout v. J.D. Byrider, 228 F.3d 709 (6th Cir. 2000) (four-step framework for court review of motions to compel arbitration)
- Mitsubishi Motors Corp. v. Soler Chrysler-Plymouth, Inc., 473 U.S. 614 (U.S. 1985) (federal courts determine whether parties agreed to arbitrate disputes)
- Hilton v. Midland Funding, LLC, [citation="687 F. App'x 515"] (6th Cir. 2017) (dismissal appropriate when parties do not request a stay pending arbitration)
