Mary Triplet v. Menard, Inc., No. 21-3157 (8th Cir. 2022)
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Plaintiff, a woman with severe autism, and her mother, filed an employment discrimination lawsuit against Menards. Plaintiff's mother, who was also a plaintiff in the suit, arranged to have a job coach help Plaintiff obtain employment. However, despite the coach being willing to help Plaintiff through her orientation, Menards did not allow the coach to be present. After orientation, Plaintiff signed an arbitration agreement without the opportunity to show it to her job coach. Ultimately, Plaintiff was terminated and filed this case.
Menards moved to compel arbitration. The district court denied Menards' request, resulting in this appeal.
On appeal, the Eighth Circuit held that the fact Plaintiff's mother was appointed as Plaintiff's conservator did not necessarily mean that Plaintiff lacked the ability to enter into the contract. However, the court held that the record was not sufficiently developed to determine whether the facially valid contract was revocable under the void contract defense. Thus, the Eighth Circuit vacated the district court's order denying the motion to compel arbitration, and remanded to the district court for further proceedings.
Court Description: [Kobes, Author, with Erickson and Stras, Circuit Judges] Civil case - Arbitration. Plaintiffs sued defendant after plaintiff Maggie Triplett was terminated, alleging employment discrimination in violation of the ADA, as well as several state law torts. Maggie's employment agreement contained an arbitration clause, and defendant moved to compel arbitration and stay the proceedings. The district court found the arbitration agreement was unenforceable as a matter of equity and that the state law claims were outside the scope of arbitration. Defendants appeal. While the arbitration agreement is facially valid under South Dakota law, it may be revocable under the void contract defense if Maggie, who is under a conservatorship based on her mental competency, was without understanding when she signed the agreement. The district court did not decide whether Maggie was entirely without understanding when she signed, and the decision is reversed and the case remanded for further findings on that question.
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