In Reeves, et al. v. Enterprise Products Partners, LP (10th Cir., No. 20-5020, 11/09/2021), three employees were hired by staffing companies and assigned to work for Enterprise Products. The employees sued Enterprise claiming violations of the Fair Labor Standards Act, and Enterprise moved to compel arbitration based on arbitration agreements between the employees and the staffing companies. The trial court denied the motion on the ground that Enterprise was not a signatory to the arbitration agreements. The 10th Circuit reversed.
Applying Oklahoma law, the court held that (1) Oklahoma contract law required applying an expanded equitable estoppel doctrine, and (2) the employees’ claims alleged substantially interdependent and concerted misconduct by Enterprise and the staffing companies. The court said that the employees “cannot simply plead around [the staffing companies], who would have to become crucial parties to the litigation.” While the employees may have carefully left out any claims against the staffing companies in their pleadings, the court held their claims were “inherently inseparable” and integrally related from their relationship, employment, and agreement with the staffing companies.