3:24-cv-00340•Williams v. Amazon.com Services LLC
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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>
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