Machado v. System4 LLC

Plaintiffs were individuals who entered into contracts with Defendants for the provision of janitorial services to third-party customers. Plaintiffs filed this putative class action, alleging that Defendants violated the Massachusetts Wage Act. Defendants moved to stay the court proceedings pending arbitration according to the terms of the arbitration clause contained in the parties' franchise agreements. The superior court denied the motion, concluding that the arbitration clause was unenforceable as set forth in Feeny v. Dell Inc. (Feeney I). After the United States Supreme Court decided AT&T Mobility LLC v. Concepcion, Defendants sought appellate review, which the Supreme Court granted. The Supreme Court reversed the order invalidating the arbitration in light of its interpretation of Conception and its impact on Feeney I, as set forth in Feeney II, holding (1) Massachusetts public policy in favor of class proceedings in certain contexts may no longer serve, in and of itself, as grounds to invalidate a class waiver in an arbitration agreement; and (2) in this case, Plaintiffs failed to demonstrate they lacked a practical means to pursue their claims on an individual basis. View "Machado v. System4 LLC" on Justia Law