Martinez-Gonzalez v. Elkhorn Packing Co.
United States Court of Appeals for the Ninth Circuit
25 F.4th 613 (2022)
- Written by Liz Nakamura, JD
Facts
Elkhorn Packing Company, LLC (Elkhorn) (defendant) hired Dario Martinez-Gonzalez (plaintiff), a Mexican citizen and resident, to harvest lettuce in California. Martinez-Gonzalez was the primary breadwinner for his extended family. Elkhorn paid approximately five times what Martinez-Gonzalez typically earned in Mexico, provided all transportation to and from the United States, sponsored Martinez-Gonzalez’s worker visa, and provided room and board during the harvest season. Several days after Martinez-Gonzalez arrived in California and began working, Elkhorn hosted a mass employee orientation in the parking lot of the hotel in which the migrant workers were housed. The orientation occurred at the end of the workday, and the workers were instructed to line up and sign a stack of employment documents, including an arbitration agreement, as directed by an Elkhorn supervisor. The paperwork was in Spanish, the workers’ native language. Without explaining or giving the workers a chance to read the paperwork, the Elkhorn supervisors directed the workers where to sign. The workers were not given copies of the signed paperwork. Martinez-Gonzalez voluntarily quit partway through the harvest season. Martinez-Gonzalez subsequently sued Elkhorn, alleging various labor-law violations. Elkhorn moved to compel arbitration under the arbitration agreement. The district court held that the arbitration agreement was unenforceable because it was the product of both economic duress and undue influence. Elkhorn appealed.
Rule of Law
Issue
Holding and Reasoning (Bumatay, J.)
Dissent (Rawlinson, J.)
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