Williams v. Amazon.com Services LLC

1
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
TAMMY J. WILLIAMS,
Plaintiff,
§
§
§
§
§
§
§
§
§
v. 	Civil Action No. 3:24-cv-00340-N-BT
AMAZON.COM SERVICES, LLC,
Defendant.
FINDINGS, CONCLUSIONS, AND RECOMMENDATION
OF THE UNITED STATES MAGISTRATE JUDGE
Before 	the 	Court 	is 	Plaintiff 	Tammy 	J. 	Williams’s 	Motion 	to 	Vacate
Arbitration Award, Strike Affirmative Defenses, and for Declaratory Relief and
Final Resolution of Claims (ECF No. 81) and Defendant Amazon.com Services,
LLC’s (Amazon) Motion to Confirm Arbitration Award (ECF No. 82). For the
reasons set forth below, the District Judge should DENY Williams’s Motion to
Vacate and GRANT Amazon’s Motion to Confirm.
Background
This 	dispute 	arises 	out of 	Williams’s 	injury 	allegedly 	sustained 	while
working for Amazon. According to her pro se Complaint, Williams was injured “in
the course and scope of her employment when a bundle of 30–40 pound
corrugated cardboard boxes fell on her neck, head, and right shoulder.” Second
Am. Compl. at 1 (ECF No. 19). As a result of this incident, Williams claims that she
suffered various injuries and side effects, including a traumatic brain injury. Id. at
Case 3:24-cv-00340-N-BT Document 100 Filed 12/19/25 Page 1 of 9 PageID <pageID>

2
4. Subsequently, Williams sued Amazon, alleging that Amazon “was negligent in
failing to provide claimant with a reasonably safe place to work and failing to have
policies and procedures in place to protect employees from being injured[.]”
Original Compl. at 4 (ECF No. 3).
The parties participated in arbitration through the American Arbitration
Association (AAA) which appointed an arbitrator to Williams’s matter. Def.’s Mot.
to Confirm at 1–2, ¶ 2 (ECF No. 82); see also id., Ex. 3 at 1–4 (ECF No. 82-3)
(arbitrator’s executed oath form). On March 21, 2025, the arbitrator entered an
order granting Amazon’s no-evidence motion for summary judgment, dismissing
Williams’s claims against Amazon. Def.’s Mot. to Confirm at 4, ¶ 16 (ECF No. 82);
see also id., Ex. 7 at 1–2 (ECF No. 82-7) (arbitrator’s order of dismissal).
The parties now present cross-motions concerning the arbitration award.
Williams requests that the Court vacate the arbitration award,1 while Amazon
seeks confirmation of the arbitration award. Each party timely filed responses and
replies to the pending Motions, and the Motions are now ripe for adjudication.
1 Williams also moves to strike Amazon’s affirmative defenses set forth in Amazon’s
Original Answer (ECF No. 20), arguing, among other things, that the arbitration
agreement is unenforceable, and Amazon waived its right to enforce the arbitration
agreement. See Pl.’s Mot. to Vacate at 7–9 (ECF No. 81). However, the Court
previously determined that the parties entered into a valid agreement to arbitrate,
and the arbitration agreement contains a delegation clause regarding arbitrability.
See generally Findings, Conclusions, and Recommendation of the United States
Magistrate Judge (FCR) (ECF No. 42); Order Accepting FCR (ECF No. 55).
Case 3:24-cv-00340-N-BT Document 100 Filed 12/19/25 Page 2 of 9 PageID <pageID>

3
Legal Standard
The Federal Arbitration Act (FAA) reflects a strong national policy favoring
arbitration. Cooper v. WestEnd Cap. Mgmt., L.L.C., 832 F.3d 534, 543 (5th Cir.
2016) (citing to Hall St. Assocs., L.L.C. v. Mattel, Inc., 552 U.S. 576, 581 (2008)).
In 	light of 	this 	strong 	policy, 	“[j]udicial 	review 	of 	an 	arbitration 	award 	is
extraordinarily narrow and [the court] should defer to the arbitrator’s decision
when possible.’” Antwine v. Prudential Bache Sec., Inc., 899 F.2d 410, 413 (5th
Cir. 1990); see also Rain CII Carbon, LLC v. ConocoPhillips Co., 674 F.3d 469,
471–72 (5th Cir. 2012).
Under the FAA, an arbitration award must be confirmed unless it is vacated,
modified, or corrected. Hall St. Assocs., 552 U.S. at 582; see also 9 U.S.C. § 10(a)
(listing grounds for vacating arbitration award); 9 U.S.C. § 11 (listing grounds for
modifying or correcting arbitration award). “The party seeking vacatur of an
arbitration award bears the burden of proof, and the reviewing court must decide
any uncertainties or doubts in favor of sustaining the award.” AdvoCare Int’l, LLC
v. Novak, 2021 WL 5890403, at *1 (N.D. Tex. Nov. 5, 2021) (Horan, J.) (citing
Soaring Wind Energy, LLC v. CATIC USA, Inc., 333 F. Supp. 3d 642, 651 (N.D.
Tex. 2018)), adopted by 2021 WL 5883137 (N.D. Tex. Dec. 10, 2021) (Godbey, J.).
The FAA permits a court to vacate an arbitration award under limited
circumstances:
(1) 	where the award was procured by corruption, fraud, or undue
means;
Case 3:24-cv-00340-N-BT Document 100 Filed 12/19/25 Page 3 of 9 PageID <pageID>

4
(2) 	where 	there 	was 	evident 	partiality 	or 	corruption 	in 	the
arbitrators, or either of them;
(3) 	where the arbitrators were guilty of misconduct in refusing to
postpone the hearing, upon sufficient cause shown, or in
refusing 	to 	hear 	evidence 	pertinent 	and 	material 	to 	the
controversy; or of any other misbehavior by which the rights of
any party have been prejudiced; or
(4) 	where the arbitrators exceeded their powers, or so imperfectly
executed them that a mutual, final, and definite award upon the
subject matter was not made.
9 U.S.C. § 10(a)(1) – (4). “These are the exclusive grounds on which a court may
vacate an arbitration award under the FAA.” Soaring Wind Energy, 333 F. Supp.
3d at 651.
Analysis
Williams argues vacatur is warranted under 9 U.S.C. § 10(a)(3) and (4) “due
to procedural irregularities, denial of due process, and Amazon’s failure to provide
reasonable accommodations for Plaintiff’s documented cognitive impairments[.]”
Pl.’s Mot. to Vacate at 1, 9 (ECF No. 81). For the reasons stated below, Williams’s
arguments do not support a vacatur of the arbitration award.
9 U.S.C. § 10(a)(3)
Section 	10(a)(3) 	permits 	vacatur 	of 	an 	arbitration 	award 	“where 	the
arbitrators were guilty of misconduct in refusing to postpone the hearing . . . or in
refusing to hear evidence pertinent and material to the controversy; or of any other
misbehavior by which the rights of any party have been prejudiced.” 9 U.S.C.
§ 10(a)(3). Williams contends that vacatur is appropriate under this section
Case 3:24-cv-00340-N-BT Document 100 Filed 12/19/25 Page 4 of 9 PageID <pageID>

5
because the arbitrator and Amazon failed to accommodate Williams’s “cognitive
impairments,” which resulted in “fundamental unfairness” and prevented her from
meaningfully participating in the arbitration Pl.’s Mot. to Vacate at 3–4 (ECF No.
81).
Williams cites various cases that purportedly support her argument that the
arbitrator and Amazon’s failure to provide her with reasonable accommodations
rendered the arbitration fundamentally unfair. See id. at 2–4; Pl.’s Reply at 2–3
(ECF No. 87). However, none of these cases support Williams’s position. See
Tennessee v. Lane, 541 U.S. 509, 533–34 (1978) (determining that Title II of the
Americans with Disabilities Act, as it applies to cases implicating the fundamental
right of physical access to the courts, was a valid exercise of Congressional power);
Gilmer v. Interstate/Johnson Lane Corp., 500 U.S. 20, 23 (1991) (holding that
claims brought pursuant to the Age Discrimination in Employment Act could be
compelled to arbitration); EEOC v. Chevron Phillips Chem Co., 570 F.3d 606, 621–
22 (5th Cir. 2009) (concluding that summary judgment was improper because
there was a genuine question of whether the employer engaged in the interactive
process required by the Americans with Disabilities Act); Robertson v. Las Animas
Cnty. Sheriff’s Dep’t, 500 F.3d 1185, 1198 (10th Cir. 2007) (analyzing whether there
was 	a 	genuine 	issue 	of 	fact 	regarding 	defendant’s 	knowledge 	of 	plaintiff’s
disability); Int’l Chem. Workers Union v. Columbian Chems. Co., 331 F.3d 491,
(5th Cir. 2003) (finding that vacatur was not appropriate because the arbitration
hearing was not fundamentally unfair). Amazon correctly notes that “Williams
Case 3:24-cv-00340-N-BT Document 100 Filed 12/19/25 Page 5 of 9 PageID <pageID>

6
provides no . . . legitimate authority supporting the conclusion that vacatur of the
[a]rbitration [a]ward is justified based on an alleged failure of Amazon (Williams’s
former employer) to provide a reasonable accommodation in the arbitration and
litigation process.” Def.’s Resp. at 8 (ECF No. 86).
Further, 	the 	record 	indicates 	that 	Williams 	was 	given 	meaningful
opportunities to participate in the arbitration. Indeed, Williams initiated the
arbitration and participated in the arbitration process through her now-withdrawn
counsel. See Pl.’s Mot. to Vacate, Ex. 2 at 1–4 (ECF No. 81-2) (Williams’s
Specification of Claims); Ex. 3 (Williams’s demand for arbitration) (ECF No. 81-
3); Ex. 4 (portions of Williams’s draft written discovery responses) (ECF No. 81-
4). Williams also attended at least one arbitration hearing on her own behalf and
filed a response to Amazon’s no-evidence motion for summary judgment. See Pl.’s
Mot. to Vacate at 6 (ECF No. 81); Def.’s Mot. to Confirm at 3, ¶¶ 13–15 (ECF No.
82).
Although Williams alleges that the arbitrator allowed her former counsel to
withdraw without her consent, leaving her to proceed in arbitration pro se, “the
Sixth Amendment right to counsel does not apply to civil proceedings, such as the
arbitration of [Williams’s claims].” Parker v. JC Penney Corp., Inc., 426 F. App’x
285, 288–89 (5th Cir. 2011) (per curiam) (rejecting pro se litigant’s argument that
lack of legal representation during arbitration proceedings warranted vacatur of
arbitration award). The record shows that the arbitrator gave Williams the
opportunity to obtain substitute legal representation after her former counsel
Case 3:24-cv-00340-N-BT Document 100 Filed 12/19/25 Page 6 of 9 PageID <pageID>

7
withdrew, but for unknown reasons, Williams did not, or could not, obtain new
counsel. See Pl.’s Mot. to Vacate, Ex. 3 at 22, 24, 30 (ECF No. 81-3) (explaining
that Williams’s arbitration proceedings would be abated until the earlier of
February 22, 2024, or the entrance of appearance of Williams’s new counsel).
Accordingly, Williams has not met her burden of demonstrating that vacatur
is appropriate under 9 U.S.C. § 10(a)(3).
9 U.S.C. § 10(a)(4)
Section 	10(a)(4) 	permits 	vacatur 	of 	an 	arbitration 	award 	“where 	the
arbitrators exceeded their powers, or so imperfectly executed them that a mutual,
final, and definite award upon the subject matter was not made.” 9 U.S.C.
§ 10(a)(4). Williams argues that the arbitrator exceed his authority by dismissing
“‘all claims’ including those contractually excluded from arbitration.” Pl.’s Mot. to
Vacate at 2 (ECF No. 81). Specifically, Williams states that claims “related to [her]
workplace injury and her denial of ERISA-based benefits . . . were improperly
compelled to arbitration, despite being carved out in the agreement itself.” Id. at
4.
Williams misunderstands the arbitrator’s order dismissing her claims.
Williams asserted claims related to her workplace injury that occurred during her
employment with Amazon. The Court expressly found that those claims were
subject to arbitration, and that the arbitration agreement delegated the issue of
arbitrability to the arbitrator. See FCR at 10–13 (ECF No. 42) (finding that the
arbitration agreement covers claims arising from any injury suffered while in the
Case 3:24-cv-00340-N-BT Document 100 Filed 12/19/25 Page 7 of 9 PageID <pageID>

8
course of employment). And the arbitrator limited the dismissal to any claims
asserted in that particular arbitration. Def.’s Mot. to Confirm, Ex. 7 at 2 (ECF No.
82-7) (“[A]ll claims asserted by Tammy Williams in this arbitration are hereby
dismissed with prejudice.”) (emphasis added). As the arbitrator did not exceed his
authority, vacatur is not appropriate under 9 U.S.C. § 10(a)(4).
Recommendation
For the foregoing reasons, the District Judge should DENY Williams’s
Motion 	to 	Vacate 	Arbitration 	Award, 	Strike 	Affirmative 	Defenses, 	and 	for
Declaratory Relief and Final Resolution of Claims (ECF No. 81) and GRANT
Amazon’s Motion to Confirm Arbitration Award (ECF No. 82).
SO RECOMMENDED.
December 19, 2025.
REBECCA RUTHERFORD
UNITED STATES MAGISTRATE JUDGE
Case 3:24-cv-00340-N-BT Document 100 Filed 12/19/25 Page 8 of 9 PageID <pageID>

9
INSTRUCTIONS FOR SERVICE AND
NOTICE OF RIGHT TO APPEAL/OBJECT
A copy of this report and recommendation shall be served on all parties in
the manner provided by law. Any party who objects to any part of this report and
recommendation must file specific written objections within 14 days after being
served with a copy. See 28 U.S.C. § 636(b)(1); Fed. R. Civ. P. 72(b). To be specific,
an objection must identify the specific finding or recommendation to which
objection is made, state the basis for the objection, and specify the place in the
magistrate judge’s report and recommendation where the disputed determination
is found. An objection that merely incorporates by reference or refers to the
briefing before the magistrate judge is not specific. Failure to file specific written
objections will bar the aggrieved party from appealing the factual findings and legal
conclusions of the magistrate judge that are accepted or adopted by the district
judge, except upon grounds of plain error. See Douglass v. United Servs. Auto.
Ass’n, 79 F.3d 1415, 1417 (5th Cir. 1996).
Case 3:24-cv-00340-N-BT Document 100 Filed 12/19/25 Page 9 of 9 PageID <pageID>