Use the IRAC Method to breifly identify the Issue, the Legal Rule (Legal Test),
ID: 351086 • Letter: U
Question
Use the IRAC Method to breifly identify the Issue, the Legal Rule (Legal Test), the Facts Applied to the Test (Analysis), and the Conclusion/ Holding of the following case:
PAK Foods Houston, LLC v. Garcia
Court of Appeals of Texas, Houston (14th District), 433 S.W.Jd 171 (2014).
Background and Facts S.L., a female sixteen-year-old minor, worked at a KFC Restaurant operated by PAK Foods Houston, LLC. PAK Foods' policy was to resolve any dispute with an employee through arbitration. At the employer’s request, S.L. signed an acknowledgment of this policy. S.L. was injured on the job and subsequently terminated her employment. S.L.'s mother, Marissa Garcia, filed a suit on S.L.'s behalf in a Texas state court against PAK Foods to recover the medical expenses for the injury. PAK Foods filed a motion to compel arbitration. The court denied the motion. 'To the extent any agreement to arbitrate existed between S.L. and PAK Foods Houston, LLC, S.L. voided such agreement by filing this suit." PAK Foods appealed.
In the Language of the Court
Martha Hill jAMISON, Justice.
* * * It is undisputed S.L. was a 16-year-old minor when the arbitration agreement was executed and she remained a minor during her employment by PAK Foods, including at the time of her injury. In Texas, the age of majority is 18 years.
It has long been the law in Texas that a contract executed by a minor is not void, but it is voidable by the minor. *** [A minor’s contracts] may be either disaffirmed by the minor or ratified afier the minor reaches majority. This means that the minor may set aside the entire contract at her option. [Emphasis added.] Appellees assert that S.L. elected to void any agreement to arbitrate by filing the underlying suit.
* * * *
PAK Foods argues that * * * S.L. was an at-will employee and did not execute an employment contract. PAK Foods also notes that S.L. did not notify PAK Foods prior to filing suit that she was voiding the arbitration agreement. These distinctions do not alter the settled law that a minor may void a contract at her election. The arbitration agreement is a contract with a minor, S.L., who had the option to disaffirm the contract.
While appellees assert that S.L. voided the agreement by filing suit, the mere filing of suit may not necessarily disafifirm an arbitration agreement. A party may file suit but later determine arbitration is appropriate. Flere, appellees’ original petition does not expressly disaffirm an agreement to arbitrate; the petition is silent about arbitration. However, appellees’ response filed in opposition to the motion to compel arbitration is a definitive disaffirmance of any agreement to arbitrate. The response states in relevant part:
S.L. was a minor at the time of her employment. * * * Contracts such as this Arbitration Agreement are voidable at her instance, and may be disaffirmed or repudiated by her or her guardian, * * * . Thus as S.L.’s disaffirmance of the Arbitration agreement has manifestly occurred with her termination of employment and election to file suit, she cannot be bound by the terms of the Arbitration Agreement.
S.L. was still a minor when she objected to arbitration and elected to void the contract. The record contains sufficient evidence of her election to support the trial court’s fact finding. The trial court also did not abuse its discretion in concluding as a matter of law that S.L.’s action voided the contract.
Decision and Remedy A state intermediate appeiiate court affirmed the decision of the iower court. A minor may disaffirm a contract at his or her option. S.L opted to disaffirm the agreement to arbitrate by terminating her empioyment and fiiing the lawsuit.
Use the IRAC Method to breifly identify the Issue, the Legal Rule (Legal Test), the Facts Applied to the Test (Analysis), and the Conclusion/ Holding of the case.
Explanation / Answer
1. Issue:
The issue here is whether S.L. effectively disaffirmed the agreement to arbitrate with her employer. Disaffermance means legally avoiding a contractual obligation.
2. Rule:
In Texas like almost every other states, the age of majority is 18 for all contractual puposes. As per law a minor has an option to make the contract voidable by disafferming it, showing clear intentions to do the same. "A Minor may void a contract as per his/her election.
3. Analysis:
When the arbitration agreement was made between SL and her employer, she was a minor. PAK Foods argued that she did not execute an employment contract and did not notify them prior to filing suit that she was voiding the arbitration contract. The arbitration contract was a contract which SL had decided to disafferm at her election. PAK foods filed a motion to compel the arbitration which was denied by court as SL's disaffermance of the arbitration contract had manifestly occured with her termination of employment and decision to file lawsuit , therefore she can not be bound by terms of Arbitration contract.
4. Conclusion
The response filed by SL in opposition to the motion to compel arbitration is a definitive disaffermance of any agreement to arbitrate. There was sufficient evidences of her election to support trial court's fact finding. It was concluded that SL's actions voided the contract by terminating her employment and filing the lawsuit. A minor may disafferm a contract at his/her option.
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