Aldea-Tirado v. PricewaterhouseCoopers, LLP, No. 22-1806 (1st Cir. 2024)
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Jennifer D. Aldea-Tirado, an employee of PricewaterhouseCoopers LLP (PWC), filed a lawsuit against her employer alleging violations of Title VII of the Civil Rights Act, the Pregnancy Discrimination Act of 1978, and Puerto Rico law. Aldea-Tirado claimed she was subjected to adverse employment action due to her gender and pregnancy and was retaliated against for filing a complaint with the United States Equal Employment Opportunity Commission. PWC, however, argued that Aldea-Tirado's employment contract contained an arbitration clause and moved to compel arbitration.
The United States District Court for the District of Puerto Rico granted PWC's motion to compel arbitration. The court determined that PWC had established the existence of a valid agreement between PWC and Aldea-Tirado to arbitrate her claims. The court also found that Aldea-Tirado had tacitly consented to the Agreement by continuing to work for PWC after having received the Agreement through both regular mail and email. Aldea-Tirado appealed this decision.
The United States Court of Appeals for the First Circuit affirmed the lower court's decision. The appellate court found no merit in Aldea-Tirado's arguments that she did not receive the Agreement or that it was unconscionable to hold her to it. The court also rejected Aldea-Tirado's contention that she was not given "some minimal level of notice" that her continued employment would effect a waiver of her right to pursue her claims in a judicial forum. The court concluded that Aldea-Tirado failed to show that there was any non-speculative basis in the record from which a reasonable factfinder could determine that she did not receive the email to which the Agreement was attached.
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