02-26-2025
In an unpublished opinion, the Sixth Circuit Court of Appeals confirmed that if an employee signs an arbitration agreement, that provision is binding and enforceable. The Federal Arbitration Act requires the enforcement of arbitration agreements unless grounds “exist at law or in equity for the revocation of any such contract.”
John Gavette lost his job at United Wholesale Mortgage, LLC (UWM). He believed UWM fired him because he requested accommodation to take care of his disabled wife. Gavette sued for violation of federal and state disability laws. The company responded that Gavette had signed an arbitration provision included in his employment contract, so he could not file a suit. Gavette argued that he did not recall signing the agreement. Moreover, UWM gave him the documents without enough time to review them or let him know he could seek legal advice. Gavette did not dispute his electronic signature on the contract.
The Michigan-based appellate court stated that it was irrelevant whether Gavette read the agreement, understood the arbitration clause, or received any legal assistance from his employer. State law governed whether the arbitration clause was validly obtained. In Michigan, “one who signs a contract will not be heard to say. . .that he did not read it, or that he supposed it was different in its terms.” Gavette was responsible for his decision to sign the agreement. His lack of understanding of the contract’s terms was “negligence,” which precluded him from voiding the agreement. He did not present circumstances that “fairly excus[ed]” him for failing to inform himself.