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Stephens v. Charter Communications Holdings, LLC
3:17-cv-00354
W.D. Ky.
Sep 26, 2017
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Background

  • 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)
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Case Details

Case Name: Stephens v. Charter Communications Holdings, LLC
Court Name: District Court, W.D. Kentucky
Date Published: Sep 26, 2017
Docket Number: 3:17-cv-00354
Court Abbreviation: W.D. Ky.