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Case 5.1
RENT-A-CENTER, WEST, INC. V. ANTONIO JACKSON
Supreme Court of the United States
561 U.S. 63; 130 S. Ct. 2772; 2010 LEXIS 4981 [June 21, 2010]
FACTS:
Antonio Jackson works for Rent-A-Center and signed a Mutual Agreement to Arbitrate Claims as a
condition of his employment.
The Agreement provides that all disputes arising out of Jackson’s employment will be arbitrated.
The Agreement states that claims for discrimination and claims for violation of any federal law
would be arbitrated, not litigated.
The Agreement also provided that the “Arbitrator, and not any federal, state, or local court or
agency, shall have exclusive authority to resolve any dispute relating to the interpretation,
applicability, enforceability, or formation of their Agreement including, but not limited to any claim
that all or part of this Agreement is void or voidable.”
On February 1, 2007 Jackson filed a federal lawsuit claiming that Rent-A-Center had discriminated
against Jackson based on his race.
Rent-A-Center filed a motion to dismiss or stay the lawsuit and to compel arbitration.
Jackson responded claiming that the Arbitration Agreement was unconscionable under Nevada law
and unenforceable.
PROCEDURE: The District Judge held for Rent-A-Center and compelled arbitration. The Court of
Appeals reversed.
ISSUE: Whether a court may decide a claim that an arbitration agreement is unconscionable where the
agreement explicitly assigns that decision to the arbitrator?
RULE: “Under the FAA, where an agreement to arbitrate includes an agreement that the arbitrator will
determine the enforceability of the agreement, if a party challenges specifically the enforceability
of that particular agreement, the district court considers the challenge, but if a party challenges the
enforceability of the agreement as a whole, the challenge is for the arbitrator.”
REASONING:
1. The FAA reflects the fundamental principle that arbitration is a matter of contract. The FAA places
arbitration agreements on an equal footing with other contracts and requires courts to enforce
ADDITIONAL INFORMATION:
The Court of Appeals decision was reversed in a 5-4 decision.
There are two types of validity challenges, one challenges specifically the validity of the agreement
