Minimum Wage Laws-Arbitration Agreement Dispute

7^th Circuit Court of Appeals

Case Name: Rashaan Carter v. SP Plus Corporation

Case No.: 25-2127

Officials: Asterbrook, Pryor, and Maldonado, Circuit Judges.

Focus: Minimum Wage Laws-Arbitration Agreement Dispute

Carter filed suit against his employer, SP Plus Corporation, alleging violations of both state and federal minimum wage laws. The company asserted that, during the onboarding process, Carter had agreed to arbitrate all claims by checking a box and providing an electronic signature. Carter, however, later submitted an affidavit stating that a member of SP Plus’s human resources team had completed and signed the documents on his behalf without explaining their contents or giving him the opportunity to review or decline them.

Initially, the Northern District of Illinois granted SP Plus’s motion to stay the case pending arbitration, relying on the onboarding records. After considering Carter’s affidavit disputing his assent, the court revisited its decision, lifted the stay, and denied the motion. The court explained that the existing record did not establish the formation of a valid arbitration agreement and noted that neither party had been given proper notice or an opportunity for a hearing to determine whether Carter had personally agreed to arbitrate.

SP Plus argued to the Seventh Circuit that the order was appealable and that arbitration should have been compelled. The court found that SP Plus forfeited any right to an evidentiary hearing by failing to request one or present evidence to counter Carter’s affidavit at the district court level. Additionally, the court determined that the district court’s ruling constituted a final denial of the motion to compel arbitration and found no clear error in its conclusion that Carter had not agreed to arbitrate.

Affirmed.

Decided 04/15/26

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