Young Mens Christian Association of Greater El Paso, Texas and Rio Grande Valley and Fred and Maria Loya YMCA v. Jose G. Garcia, 361 S.W.3d 123

Garcia worked for YMCA from 1997 to early 2010 and suffered a December 2009 on-the-job injury.
After returning to light duty in January 2010, YMCA offered reduced hours and loss of benefits; Garcia refused and was terminated.
Garcia filed suit alleging age/race discrimination and retaliatory discharge for workers’ compensation pursuit.
YMCA moved to compel arbitration based on a dispute resolution policy in the personnel policy manual signed by Garcia in 2004.
Manual states it is not a contract and may be unilaterally changed; dispute policy requires final and binding arbitration under FAA.
Trial court denied arbitration; YMCA appealed interlocutorily under FAA procedures; issue centered on validity of the arbitration clause.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the parties form a valid arbitration agreement?	Garcia argues the manual disclaims contract creation and reserves unilateral change, negating arbitration.	YMCA contends the dispute resolution policy is a binding arbitration agreement despite disclaimers.	No valid arbitration agreement; order to compel arbitration affirmed.

Mitsubishi Motors Corp. v. Soler Chrysler-Plymouth, Inc., 473 U.S. 614 (1985) (FAA arbitration questions governed by federal law; contract formation principles apply)
In re Palm Harbor Homes, Inc., 195 S.W.3d 672 (Tex. 2006) (state law contract formation governs arbitration agreements under FAA)
In re Kellogg Brown & Root, Inc., 166 S.W.3d 732 (Tex. 2005) (Texas contract principles apply to arbitration agreement validity)
J.M. Davidson, Inc. v. Webster, 128 S.W.3d 223 (Tex. 2003) (burden shifting in arbitration: show valid agreement, then affirmative defenses)
Forbau v. Aetna Life Insurance Company, 876 S.W.2d 132 (Tex. 1994) (specific contract language controls over general boilerplate language)
In re AdvancePCS Health L.P., 172 S.W.3d 603 (Tex. 2005) (establishes standard for determining existence of a valid arbitration agreement)