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Court Case Summary

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HEB Grocery Co. v. Perez

Citation:

HEB Grocery Co. v. Perez, No. 13-18-00063-CV, 2019 WL 3406609 (Tex. App.—Corpus Christi–Edinburg July 25, 2019, mem. op.)

Court & Date

  • Court: Texas Court of Appeals, Thirteenth District (Corpus Christi–Edinburg)
  • Date: July 25, 2019

Opinion by: Justice Hinojosa

Facts

    • Employment Application: Yolanda Perez applied for a job with HEB through an online application.
    • Arbitration Agreement:
      • The application included an Agreement to Arbitrate requiring all disputes related to hiring, employment, benefits, separation, or occupational injuries to be resolved exclusively by binding arbitration under the FAA.
      • Perez had to review this agreement before completing the application and affirmatively answered “Yes” to a question confirming she understood and agreed.
    • Dispute: Perez later brought claims against HEB in court. HEB moved to compel arbitration.

    Trial Court: Denied HEB’s motion to compel arbitration.

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Issue

  • Whether the arbitration agreement in HEB’s online employment application was valid and enforceable, requiring Perez’s claims to be arbitrated.

Holding

  • Reversed and Remanded.

The Court of Appeals held that Perez did agree to arbitrate her claims, and the trial court erred in refusing to compel arbitration.

Reasoning

  1. Mutual Assent: Perez had notice of the arbitration agreement and affirmatively assented by clicking “Yes.”
  2. FAA Policy: The agreement expressly invoked the FAA, which strongly favors arbitration.
  3. Scope: The arbitration clause was broad and covered Perez’s claims.

 Significance – Power of Arbitration Agreements

    • Employment Context: Online arbitration agreements are enforceable if the applicant has notice and affirmatively assents.
    • Judicial Deference: Texas courts will enforce arbitration agreements broadly and overturn trial courts that improperly deny arbitration.
    • Practical Effect: Arbitration agreements can completely redirect disputes away from court, even before substantive issues like liability or damages are reache

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