Ragland v. IEC US Holdings, Inc.

Natalie Ragland (plaintiff) filed suit against IEC US Holdings, Inc. (IEC) (defendant), alleging age discrimination and retaliation in violation of state and federal law. IEC moved to compel arbitration, asserting that Ragland was bound by its arbitration agreement. Ragland opposed the motion, arguing that no valid arbitration agreement existed. She stated that after receiving her offer letter and the arbitration agreement, she called IEC’s business office manager, Barbara Perez, to ask what to do if she was unwilling to sign the arbitration agreement. According to Ragland, Perez instructed her to indicate her refusal, so she wrote “No Refused” on the signature line and returned the document. Perez disputed this account, testifying that she did not recall Ragland refusing to sign the arbitration agreement and believed Ragland had signed using words resembling “Na Ragland.” While IEC did not dispute that the words on the signature line actually said “No Refused,” it contended that Ragland nonetheless assented to arbitration because she knew that agreeing to arbitration was a condition of employment. IEC argued that by signing her employment application and offer letter—both of which referenced the arbitration requirement—and by commencing employment, Ragland manifested acceptance. However, the employment application expressly stated that it did not constitute a contract, and the offer letter required Ragland to sign and return the separate arbitration agreement. The district court denied IEC’s motion to compel arbitration, finding that Ragland’s express refusal nullified any prior manifestations of assent and that IEC accordingly failed to prove the existence of a valid arbitration agreement. IEC appealed.