The U.S. District Court for the Southern District of Florida held that a scrivener’s error identifying the wrong entity as employer did not preclude enforcement of an arbitration clause in an employment agreement.
Florida resident Eldiberto Garcia brought a Fair Labor Standards Act claim against his former employer Mason Contract Products, LLC, which then sought to compel arbitration in New York pursuant to a written employment agreement signed by Mr. Garcia. The agreement incorrectly identified MRC Industries—a company affiliated with Mason but neither its parent nor subsidiary—as employer. Although the company official who signed the document was a principal of both Mason and MRC, the document made no reference to Mason, and thus Mr. Garcia argued that Mason could not compel him to arbitrate in New York.
The district court stated that it was “personally sympathetic with Garcia,” but held that precedent compelled enforcement on the grounds of estoppel, noting that “arbitration agreements are widely and broadly enforced in the Eleventh Circuit.” (Garcia v. Mason Contract Products, LLC, No. 08 Civ. 23103, 2010 WL 520805 (Feb. 9, 2010))