Friend v. Haleon US Holdings Inc.

U.S. District Court, District of Minnesota

Friend v. Haleon US Holdings Inc.

Trial Court Opinion

             UNITED STATES DISTRICT COURT                            
                 DISTRICT OF MINNESOTA                               
              CIVIL NO. 24-648 (DSD/ECW)                             

Kenneth Friend,                                                           

               Plaintiff,                                            
v.                                           ORDER                        
Haleon US Holdings, Inc.,                                                 

               Defendant.                                            


This  matter  is  before  the  court  upon  defendant  Haleon  US    
Holdings,  Inc.’s   motion  to   compel  arbitration   and  stay          
proceedings.    Based  on  a  review  of  the  file,  record,  and        
proceedings herein, and for the following reasons, the motion is          
granted.                                                                  

                      BACKGROUND1                                    
This  employment  dispute  arises  from  plaintiff   Kenneth         
Friend’s  termination  by  his  employer  Haleon  US  Holdings,  Inc.     
(Haleon).  Friend worked for Haleon and its predecessor company           
beginning  in  1987.    Compl.  ¶  11.    In  September  2023,  Haleon    
informed Friend that he was terminated due to violations of the           
company’s code of conduct and confidentiality policy.  Id. ¶¶ 83-         
84.  Friend denies any engaging in any wrongdoing.  Because he was        

1 This order will only recite facts relevant to the issues           
presented.                                                                
terminated for misconduct, Haleon did not offer him severance.            
Id. ¶¶ 91-92.                                                             
On  March  1,  2024,  Friend  commenced  this  action  alleging      

interference  in  violation  of  the  Employee  Retirement  Income        
Security Act (ERISA), violation of the Minnesota Human Rights Act,        
and violation of the Americans with Disabilities Act.  Haleon now         
moves to compel arbitration based on its Helping Employees Achieve        
Resolution of their concerns at work program (HEAR).  Friend denies       
agreeing to participate in the HEAR program and argues that his           
ERISA claim is beyond its scope in any event.                             
The HEAR program launched on August 1, 2018.  King Decl. ¶ 5;        
id. Ex. A, at 4.  The program includes the following four-step            
approach to resolving workplace disputes: (1) share concerns with         
managers or through another “speak up” channel; (2) contact human         
resources (HR); (3) if still unresolved, initiate mediation before        

an independent third party; and (4) if mediation is unsuccessful,         
initiate  arbitration.    King  Decl.  ¶  6;  id.  Ex.  A,  at  1.    If  
employees did not opt out of the HEAR program by August 31, 2018,         
they were bound by its terms.  King Decl. ¶ 7.                            
Haleon  informed  employees,  including  Friend,  of  the  HEAR      
program repeatedly and in several ways.  First, Haleon sent two           
emails - dated August 1 and August 15 – to employees regarding the        
HEAR program.  See King Decl. Ex. D.  The first email introduced          
the HEAR program and explained its terms in detail, including the         
opt-out procedure.  See id.  It included a link to the HEAR webpage       
on  the  company’s  intranet  system,  which  further  described  and     
explained the program, answered frequently asked questions, and           

provided the opt-out form.  See id. Ex. F.  The HEAR page also            
included the HEAR Legal Agreement for employee review.  See id.           
Ex. D, at 2; see id. Ex. A.  The HEAR Legal Agreement goes into           
greater detail about each step of the HEAR program, including in-         
depth information about the agreement to arbitrate.  See id. Ex.          
A.  The second email reiterated the information provided in the           
first email, including a reminder to opt-out by August 31, and            
provided links to the HEAR page and to the HR support center.  King       
Decl. ¶ 16.                                                               
Second, on August 9, Haleon posted an article on the HEAR            
page explaining the program and the opt-out procedure and directing       
employees with questions to the HR support center.  King Decl. Ex.        

G.                                                                        
Third, the August 23 company newsletter’s “To Know. To Do.”          
section included a reference to the HEAR email and asked: “Have           
you decided which choice is best for you?”  Id. Ex. H.                    
Haleon has received data indicating that Friend received both        
emails though his work account, and that he opened the first email        
six times.  Id. ¶ 17.  It is unclear whether he clicked on any            
links included in the emails or if he ever visited the HEAR page.         
Friend did not opt out of the HEAR program.  Grogan Decl. ¶ 7.            
Friend denies being aware of the “HEAR Legal Agreement” during       
his employment,2 and does not recall reviewing any emails about           
the program.  Friend Decl. ¶ 10.  He also maintains that he was           

unaware of the opt-out process.  Id. ¶ 14.  He admits, however,           
that he “may” have opened an email “regarding changes to how Haleon       
deals with employment related disputes.”  Id. ¶ 12.                       
The narrow question now before the court is whether Friend,          
having failed to opt out, is bound by the HEAR agreement and must         
arbitrate his claims.                                                     

                      DISCUSSION                                     
Congress  enacted  the  Federal  Arbitration  Act  (FAA)  to         
counteract  “longstanding   judicial  hostility  to   arbitration         
agreements”  by  “plac[ing] arbitration  agreements  upon  the  same      
footing as other contracts.”  E.E.O.C. v. Waffle House, Inc., 
534 U.S. 279, 289
 (2002) (quoting Gilmer v. Interstate/Johnson Lane           
Corp., 
500 U.S. 20, 24
 (1991)).  The role of the court is limited         
to  determining  the  existence  and  scope  of  an  agreement  to        
arbitrate.  Gannon v. Circuit City Stores, Inc., 
262 F.3d 677, 680
        
(8th Cir. 2001).  Whether a valid agreement to arbitrate formed is        

2 Friend seems to be splitting hairs.  He specifically denies        
being aware of the “HEAR Legal Agreement” while also acknowledging        
that he “may” have been aware of the HEAR program.  Friend Decl.          
¶¶ 10, 12.  As will be discussed, Friend’s stated unfamiliarity           
with the legal agreement itself does not preclude a finding that          
he is subject to its terms.                                               
a  question  of  contract.   Keymer  v.  Mgmt.  Recruiters  Int’l,        
Inc., 
169 F.3d 501, 504
 (8th Cir. 1999).                                  
“In determining whether the parties have agreed to arbitrate,        

state law contract principles apply, in accordance with the general       
policies  governing  arbitration  agreements.”    Yufan  Zhang  v.        
UnitedHealth  Grp.,  
367 F. Supp. 3d 910, 914
  (D.  Minn.  2019).    
“Under Minnesota law, a contract is formed when: 1) there is a            
definite offer; 2) acceptance of the offer; and 3) consideration.”        
Id.
  (citing  Thomas  B.  Olson  &  Assoc.,  P.A.  v.  Leffert,  Jay  &   
Polglaze, P.A., 
756 N.W.2d 907, 918
 (Minn. Ct. App. 2008)).               
An offer must be “definite in form and must be communicated          
to the employee.”  Lang v. Burlington No. R. Co., 
835 F. Supp. 1104, 1106
 (D. Minn. 1993).  Haleon argues that the August 1, 2018,       
email constituted an offer because it provided specific language          
explaining  the  HEAR  program,  the  import  of  the  arbitration        

agreement, and the opt-out procedure.  See King Decl. Ex. D.  The         
email also provided a link to the HEAR page, which contained the          
HEAR Legal Agreement and additional details about the program.            
Id. at 2.                                                                 
Friend responds that the email does not constitute an offer          
because  he  does  not  recall  clicking  on  the  HEAR  page  link  or   
accessing the HEAR Legal Agreement.  But his recollection, or lack        
thereof,  does  not  dictate  whether  a  definite  offer  was  indeed    
communicated to him.  The record shows that it was and that he            
received numerous reminders of the offer during the opt-out period.       
The record also shows that he opened the August 1 email six times,        
which demonstrates that he received it and was curious enough to          

open it repeatedly.  The fact that he may not have read the HEAR          
Legal Agreement is irrelevant given that it was made available to         
him and referenced in several communications throughout the opt-          
out period.  Under these circumstances, Friend’s failure to review        
Haleon’s offer - or recall whether he did - is irrelevant.                
Haleon asserts that Friend accepted the offer by failing to          
opt out within the time permitted.  Friend argues that he could           
not have agreed to the HEAR Legal Agreement because he never saw          
that document.  He also denies being aware of the deadline to opt         
out of the HEAR program.  As above, Friend’s arguments in this            
regard are unpersuasive.  He received the information he needed to        
make an informed decision as to whether he would agree to arbitrate       

workplace disputes.  That information included details regarding          
how to decline Haleon’s offer by opting out of the HEAR program.          
By failing to do so, he accepted the offer to arbitrate.  See             
McMurray  v.  AT&T  Mobility  Servs.,  LLC,  No.  21-cv-414,  
2021 WL 3293540
,  at  *4  (D.  Minn.  Aug.  2,  2021)  (where  the  employer      
presented plaintiff with “a clear choice of whether or not to             
accept  the  Arbitration  Agreement  and  provided  him  specific         
instructions on how to opt out[,]” his failure to opt out “plainly        
indicated acceptance of the Arbitration Agreement”).                      
Further, the fact that neither party signed the arbitration          
agreement is immaterial.  It is well recognized that a signature          
is not required to form a contract in Minnesota or under the FAA.         

See 
id.
 *4 n.5 (citing Gorham v. Benson Optical, 
539 N.W.2d 798, 800
  (Minn.  Ct.  App.  1995);  Rust  Consulting,  Inc.  v.  Schneider    
Wallace Cottrell Konecky Wotkyns, LLP, No. 17-cv-4981, 
2019 WL 3456891
, at *3-4 (D. Minn. July 31, 2019); Filson v. Radio Advert.        
Mktg. Plan, LLC, 
553 F. Supp. 2d 1074, 1086
 (D. Minn. 2008)).             
The court also finds that that the agreement to arbitrate was        
supported  by  adequate  consideration  given  the  parties’  mutual      
promises.  See id. at *5 (“[U]nder Minnesota law, an exchange of          
mutual promise is adequate consideration to support a contract.).         
Friend argues that even if the arbitration agreement is valid,       
it does not apply to his ERISA claim.  The ERISA claim is based on        
Haleon’s failure to pay Friend severance after his termination.           

Haleon persuasively argues that ERISA does not apply to severance         
payments,  as  such  payments  do  not  typically  require  ongoing       
administrative services.  But resolving that issue is beyond the          
court’s purview in this case.  The arbitration agreement expressly        
states that issues “concerning arbitrability of a particular issue        
or claim ... must be resolved by the arbitrator, not the court.”          
King Decl. Ex. A, at 7.  As a result, the court will defer to the         
arbitrator on this issue.                                                 
The court denies Friend’s request for limited discovery to           
determine  what  communications  about  the  HEAR  program  Friend        
actually clicked on and opened, as such facts are irrelevant given        

the discussion above.                                                     

                      CONCLUSION                                     
Accordingly, IT IS HEREBY ORDERED that:                              
1.   The motion to compel arbitration and stay proceedings           
[ECF No. 7] is granted; and                                               
2.   This  matter  is  stayed  pending  completion  of   the         
arbitration.                                                              


Dated: May 7, 2024            s/David S. Doty                             
                         David S. Doty, Judge                        
                         United States District Court                

Trial Court Opinion

             UNITED STATES DISTRICT COURT                            
                 DISTRICT OF MINNESOTA                               
              CIVIL NO. 24-648 (DSD/ECW)                             

Kenneth Friend,                                                           

               Plaintiff,                                            
v.                                           ORDER                        
Haleon US Holdings, Inc.,                                                 

               Defendant.                                            


This  matter  is  before  the  court  upon  defendant  Haleon  US    
Holdings,  Inc.’s   motion  to   compel  arbitration   and  stay          
proceedings.    Based  on  a  review  of  the  file,  record,  and        
proceedings herein, and for the following reasons, the motion is          
granted.                                                                  

                      BACKGROUND1                                    
This  employment  dispute  arises  from  plaintiff   Kenneth         
Friend’s  termination  by  his  employer  Haleon  US  Holdings,  Inc.     
(Haleon).  Friend worked for Haleon and its predecessor company           
beginning  in  1987.    Compl.  ¶  11.    In  September  2023,  Haleon    
informed Friend that he was terminated due to violations of the           
company’s code of conduct and confidentiality policy.  Id. ¶¶ 83-         
84.  Friend denies any engaging in any wrongdoing.  Because he was        

1 This order will only recite facts relevant to the issues           
presented.                                                                
terminated for misconduct, Haleon did not offer him severance.            
Id. ¶¶ 91-92.                                                             
On  March  1,  2024,  Friend  commenced  this  action  alleging      

interference  in  violation  of  the  Employee  Retirement  Income        
Security Act (ERISA), violation of the Minnesota Human Rights Act,        
and violation of the Americans with Disabilities Act.  Haleon now         
moves to compel arbitration based on its Helping Employees Achieve        
Resolution of their concerns at work program (HEAR).  Friend denies       
agreeing to participate in the HEAR program and argues that his           
ERISA claim is beyond its scope in any event.                             
The HEAR program launched on August 1, 2018.  King Decl. ¶ 5;        
id. Ex. A, at 4.  The program includes the following four-step            
approach to resolving workplace disputes: (1) share concerns with         
managers or through another “speak up” channel; (2) contact human         
resources (HR); (3) if still unresolved, initiate mediation before        

an independent third party; and (4) if mediation is unsuccessful,         
initiate  arbitration.    King  Decl.  ¶  6;  id.  Ex.  A,  at  1.    If  
employees did not opt out of the HEAR program by August 31, 2018,         
they were bound by its terms.  King Decl. ¶ 7.                            
Haleon  informed  employees,  including  Friend,  of  the  HEAR      
program repeatedly and in several ways.  First, Haleon sent two           
emails - dated August 1 and August 15 – to employees regarding the        
HEAR program.  See King Decl. Ex. D.  The first email introduced          
the HEAR program and explained its terms in detail, including the         
opt-out procedure.  See id.  It included a link to the HEAR webpage       
on  the  company’s  intranet  system,  which  further  described  and     
explained the program, answered frequently asked questions, and           

provided the opt-out form.  See id. Ex. F.  The HEAR page also            
included the HEAR Legal Agreement for employee review.  See id.           
Ex. D, at 2; see id. Ex. A.  The HEAR Legal Agreement goes into           
greater detail about each step of the HEAR program, including in-         
depth information about the agreement to arbitrate.  See id. Ex.          
A.  The second email reiterated the information provided in the           
first email, including a reminder to opt-out by August 31, and            
provided links to the HEAR page and to the HR support center.  King       
Decl. ¶ 16.                                                               
Second, on August 9, Haleon posted an article on the HEAR            
page explaining the program and the opt-out procedure and directing       
employees with questions to the HR support center.  King Decl. Ex.        

G.                                                                        
Third, the August 23 company newsletter’s “To Know. To Do.”          
section included a reference to the HEAR email and asked: “Have           
you decided which choice is best for you?”  Id. Ex. H.                    
Haleon has received data indicating that Friend received both        
emails though his work account, and that he opened the first email        
six times.  Id. ¶ 17.  It is unclear whether he clicked on any            
links included in the emails or if he ever visited the HEAR page.         
Friend did not opt out of the HEAR program.  Grogan Decl. ¶ 7.            
Friend denies being aware of the “HEAR Legal Agreement” during       
his employment,2 and does not recall reviewing any emails about           
the program.  Friend Decl. ¶ 10.  He also maintains that he was           

unaware of the opt-out process.  Id. ¶ 14.  He admits, however,           
that he “may” have opened an email “regarding changes to how Haleon       
deals with employment related disputes.”  Id. ¶ 12.                       
The narrow question now before the court is whether Friend,          
having failed to opt out, is bound by the HEAR agreement and must         
arbitrate his claims.                                                     

                      DISCUSSION                                     
Congress  enacted  the  Federal  Arbitration  Act  (FAA)  to         
counteract  “longstanding   judicial  hostility  to   arbitration         
agreements”  by  “plac[ing] arbitration  agreements  upon  the  same      
footing as other contracts.”  E.E.O.C. v. Waffle House, Inc., 
534 U.S. 279, 289
 (2002) (quoting Gilmer v. Interstate/Johnson Lane           
Corp., 
500 U.S. 20, 24
 (1991)).  The role of the court is limited         
to  determining  the  existence  and  scope  of  an  agreement  to        
arbitrate.  Gannon v. Circuit City Stores, Inc., 
262 F.3d 677, 680
        
(8th Cir. 2001).  Whether a valid agreement to arbitrate formed is        

2 Friend seems to be splitting hairs.  He specifically denies        
being aware of the “HEAR Legal Agreement” while also acknowledging        
that he “may” have been aware of the HEAR program.  Friend Decl.          
¶¶ 10, 12.  As will be discussed, Friend’s stated unfamiliarity           
with the legal agreement itself does not preclude a finding that          
he is subject to its terms.                                               
a  question  of  contract.   Keymer  v.  Mgmt.  Recruiters  Int’l,        
Inc., 
169 F.3d 501, 504
 (8th Cir. 1999).                                  
“In determining whether the parties have agreed to arbitrate,        

state law contract principles apply, in accordance with the general       
policies  governing  arbitration  agreements.”    Yufan  Zhang  v.        
UnitedHealth  Grp.,  
367 F. Supp. 3d 910, 914
  (D.  Minn.  2019).    
“Under Minnesota law, a contract is formed when: 1) there is a            
definite offer; 2) acceptance of the offer; and 3) consideration.”        
Id.
  (citing  Thomas  B.  Olson  &  Assoc.,  P.A.  v.  Leffert,  Jay  &   
Polglaze, P.A., 
756 N.W.2d 907, 918
 (Minn. Ct. App. 2008)).               
An offer must be “definite in form and must be communicated          
to the employee.”  Lang v. Burlington No. R. Co., 
835 F. Supp. 1104, 1106
 (D. Minn. 1993).  Haleon argues that the August 1, 2018,       
email constituted an offer because it provided specific language          
explaining  the  HEAR  program,  the  import  of  the  arbitration        

agreement, and the opt-out procedure.  See King Decl. Ex. D.  The         
email also provided a link to the HEAR page, which contained the          
HEAR Legal Agreement and additional details about the program.            
Id. at 2.                                                                 
Friend responds that the email does not constitute an offer          
because  he  does  not  recall  clicking  on  the  HEAR  page  link  or   
accessing the HEAR Legal Agreement.  But his recollection, or lack        
thereof,  does  not  dictate  whether  a  definite  offer  was  indeed    
communicated to him.  The record shows that it was and that he            
received numerous reminders of the offer during the opt-out period.       
The record also shows that he opened the August 1 email six times,        
which demonstrates that he received it and was curious enough to          

open it repeatedly.  The fact that he may not have read the HEAR          
Legal Agreement is irrelevant given that it was made available to         
him and referenced in several communications throughout the opt-          
out period.  Under these circumstances, Friend’s failure to review        
Haleon’s offer - or recall whether he did - is irrelevant.                
Haleon asserts that Friend accepted the offer by failing to          
opt out within the time permitted.  Friend argues that he could           
not have agreed to the HEAR Legal Agreement because he never saw          
that document.  He also denies being aware of the deadline to opt         
out of the HEAR program.  As above, Friend’s arguments in this            
regard are unpersuasive.  He received the information he needed to        
make an informed decision as to whether he would agree to arbitrate       

workplace disputes.  That information included details regarding          
how to decline Haleon’s offer by opting out of the HEAR program.          
By failing to do so, he accepted the offer to arbitrate.  See             
McMurray  v.  AT&T  Mobility  Servs.,  LLC,  No.  21-cv-414,  
2021 WL 3293540
,  at  *4  (D.  Minn.  Aug.  2,  2021)  (where  the  employer      
presented plaintiff with “a clear choice of whether or not to             
accept  the  Arbitration  Agreement  and  provided  him  specific         
instructions on how to opt out[,]” his failure to opt out “plainly        
indicated acceptance of the Arbitration Agreement”).                      
Further, the fact that neither party signed the arbitration          
agreement is immaterial.  It is well recognized that a signature          
is not required to form a contract in Minnesota or under the FAA.         

See 
id.
 *4 n.5 (citing Gorham v. Benson Optical, 
539 N.W.2d 798, 800
  (Minn.  Ct.  App.  1995);  Rust  Consulting,  Inc.  v.  Schneider    
Wallace Cottrell Konecky Wotkyns, LLP, No. 17-cv-4981, 
2019 WL 3456891
, at *3-4 (D. Minn. July 31, 2019); Filson v. Radio Advert.        
Mktg. Plan, LLC, 
553 F. Supp. 2d 1074, 1086
 (D. Minn. 2008)).             
The court also finds that that the agreement to arbitrate was        
supported  by  adequate  consideration  given  the  parties’  mutual      
promises.  See id. at *5 (“[U]nder Minnesota law, an exchange of          
mutual promise is adequate consideration to support a contract.).         
Friend argues that even if the arbitration agreement is valid,       
it does not apply to his ERISA claim.  The ERISA claim is based on        
Haleon’s failure to pay Friend severance after his termination.           

Haleon persuasively argues that ERISA does not apply to severance         
payments,  as  such  payments  do  not  typically  require  ongoing       
administrative services.  But resolving that issue is beyond the          
court’s purview in this case.  The arbitration agreement expressly        
states that issues “concerning arbitrability of a particular issue        
or claim ... must be resolved by the arbitrator, not the court.”          
King Decl. Ex. A, at 7.  As a result, the court will defer to the         
arbitrator on this issue.                                                 
The court denies Friend’s request for limited discovery to           
determine  what  communications  about  the  HEAR  program  Friend        
actually clicked on and opened, as such facts are irrelevant given        

the discussion above.                                                     

                      CONCLUSION                                     
Accordingly, IT IS HEREBY ORDERED that:                              
1.   The motion to compel arbitration and stay proceedings           
[ECF No. 7] is granted; and                                               
2.   This  matter  is  stayed  pending  completion  of   the         
arbitration.                                                              


Dated: May 7, 2024            s/David S. Doty                             
                         David S. Doty, Judge                        
                         United States District Court                

Reference

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