Can Supervisors Enforce an Arbitration Agreement They Did Not Sign?

Plaintiff Rivera worked for Rent a Center. He sued his supervisor, Owens, for race discrimination. Owens presented an arbitration agreement between Rivera and Rent a Center and asked the court to dismiss or stay the case pending arbitration. The agreement provided arbitration of legal claims against not only Rent a Center but also against its employees. Rivera insisted that the agreement was between him and Rent a Center only.

The Cuyahoga County Court of Appeals reversed the trial court's decision denying Owen's Owens' motion. The reason? Pretty simple: Owens was a third-party beneficiary of the agreement. In short, basic agency and contract principles apply to arbitration agreements, including ones between employer and employee.  Rivera v. Rent A Center, Inc., 2015-Ohio-3765 (8th Dist., Sept, 17, 2015).