AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• Kefty Eaton was employed by SolarCity in 2014 and signed documents containing arbitration clauses on his first day, under conditions where not all laptops worked and there was pressure to quickly accept the employee handbook policies for others to use the functioning laptops. After being terminated in 2017, Eaton filed a complaint alleging employment discrimination and retaliatory discharge. SolarCity moved to dismiss and compel arbitration, which Eaton opposed, arguing lack of mutual assent to the arbitration agreement due to the circumstances under which the electronic signatures were collected (paras 2-3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant (SolarCity): Argued that Kefty Eaton signed a valid and enforceable agreement requiring him to pursue employment-related disputes in arbitration (para 1).
• Plaintiff-Appellee (Eaton): Contended that there was no mutual assent to the arbitration agreement because he did not know he was entering into an agreement to arbitrate, was not allowed to read the policies contained in the agreement, and was not provided a hard copy to review (para 7).

Legal Issues

• Whether the district court erred in declining to enforce the arbitration agreement due to a lack of mutual assent (para 4).

Disposition

• The New Mexico Court of Appeals affirmed the district court's order denying SolarCity's motion to dismiss and to compel arbitration, concluding that there was a genuine issue of material fact as to whether the arbitration agreement was supported by mutual assent (para 9).

Reasons

• The Court, led by Chief Judge J. Miles Hanisee with concurrence from Judges Jennifer L. Attrep and Kristina Bogardus, held that a legally enforceable contract, including an arbitration agreement, requires offer, acceptance, consideration, and mutual assent. The Court found that SolarCity failed to refute the district court's conclusion that there exists a genuine issue of material fact regarding mutual assent to the arbitration agreement. This was based on Eaton's affidavit, which described the pressured conditions under which the electronic signatures were collected, suggesting Eaton may not have known he was agreeing to arbitrate. SolarCity did not present evidence or arguments to dispute Eaton's claims of lack of mutual assent, nor did it address the validity of Eaton's affidavit either at the district court level or on appeal (paras 5-8).