Cardwell v. Whataburger Restaurants LLC No 14-1019

PER CURIAM.

Cardwell (Petitioner) sued her employer, Whataburger Restaurants (Respondent) to recover damages from an injury that occurred on-the-job. Respondent moved to compel arbitration based on the Employee Handbook. Petitioner raised several defenses, including an argument that the arbitration agreement was unconscionable and illusory on several theories.

The trial court denied Respondent’s motion based on findings of fact and conclusions of law. However, the trial court also based its ruling on only some of Petitioner’s unconscionability arguments, the trial court’s own views on arbitration, and some of their own research. The trial court failed to discuss all of Petitioner’s unconscionability arguments as well as the argument that the arbitration was illusory.

On appeal, Respondent argued that the trial court’s refusal to compel arbitration was an abuse of discretion. Petitioner argued that all of the other unconscionability arguments she raised required the trial court to deny arbitration. The court of appeals set out all of the parties’ arguments, but only addressed the grounds that the trial court gave for its ruling. The court of appeals concluded that the trial court had abused its discretion and remanded the case with instructions for the trial court to order arbitration. The court of appeals did not address the Petitioner’s many arguments and stated, “[A]s the trial court did not base its determination of unconscionability on those grounds, we need not consider them.”

Petitioner now argues that she raised other grounds to deny arbitration that the court of appeals did not address. The Supreme Court held that because Petitioner’s arguments were briefed by both parties, the court of appeals “must hand down a written opinion that . . . addresses every issue raised and necessary to final disposition of the appeal.” Therefore, the Supreme Court granted Petitioner’s petition for review, reversed the court of appeal’s holding, and remanded the case to the court of appeals for further proceedings.