Camara v. Mastro's Restaurants LLC, No. 18-7167 (D.C. Cir. 2020)Annotate this Case
Plaintiff filed suit against his former employer, claiming that Mastro's deprived him and other servers of a minimum wage in violation of the Fair Labor Standards Act and the District of Columbia's Minimum Wage Revision Act.
The DC Circuit affirmed the district court's denial of Mastro's motion to compel arbitration, holding that a reasonable factfinder could conclude that plaintiff was unaware of the arbitration agreement during the course of his work at Mastro's, and that he therefore had no reason to believe his continued employment could be seen as an intent to be bound by the agreement. The court held that the district judge, in a comprehensive opinion, correctly treated Mastro's motion as if it sought summary judgment under Federal Rule of Civil Procedure 56(c) with respect to the question whether plaintiff had agreed to arbitrate. In this case, Mastro's was unable to produce a copy of an arbitration agreement bearing plaintiff's signature, or any other direct evidence of his assent to be bound by the policy. Furthermore, nothing in the record negates plaintiff's sworn declaration that he was unaware of the agreement's existence and had no reason to believe he had relinquished his right to a trial.