Holmes v. Air Liquide USA, LLC
United States District Court for the Southern District of Texas
2012 U.S. Dist. LEXIS 10678 (2012)

- Written by Emily Pokora, JD
Facts
In February 2011, Jamie Holmes (plaintiff) was terminated by her employer, Air Liquide America (ALA) (defendant). Holmes sued ALA for discrimination based on her association with her disabled daughter under the Americans with Disabilities Act, on gender under Title VII of the Texas Commission on Human Rights Act (TCHRA), and on retaliation under the Family and Medical Leave Act and the TCHRA. ALA filed a motion to compel arbitration based on its arbitration agreement with Holmes. Holmes argued that the arbitration agreement was unenforceable pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank), enacted after execution of the arbitration agreement. Specifically, Holmes asserted that because the arbitration agreement could have applied to two sections of Dodd-Frank involving whistleblower protections, the entire agreement was invalid even if Holmes’s dispute asserted claims unrelated to Dodd-Frank. Holmes’s argument relied on Dodd-Frank § 1057, which stated that no arbitration agreement was enforceable “to the extent that” it applied to disputes under Dodd-Frank. ALA argued that Holmes’s broad interpretation of Dodd-Frank would void every arbitration agreement involving federal statutory claims before the statute’s enactment and was absurd.
Rule of Law
Issue
Holding and Reasoning (Ellison, J.)
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