In a significant ruling, the 11th U.S. Circuit Court of Appeals has determined that Starbucks cannot force Raphyr Lubin, the husband of a former employee, to arbitrate his claims regarding the company’s failure to provide proper notification about continuing healthcare coverage. The decision marks a crucial victory for workers’ rights under the federal Employee Retirement Income Security Act (ERISA).
The appeals court panel, in a unanimous opinion, concluded that since Lubin was never employed by Starbucks, he was not bound by the arbitration agreement his wife had signed as part of her employment with the company. The ruling stems from a 2020 lawsuit in which Lubin alleged that Starbucks did not adequately inform him and other beneficiaries of their right to enroll in continuing health coverage under COBRA, after his wife lost her job.
Lubin and his wife, who was terminated from her position at Starbucks in early 2019, each received a COBRA notification from the company’s healthcare plan administrator. However, the notice failed to include essential information, such as how to enroll and where to send payments—requirements under ERISA. Lubin, along with another former Starbucks employee, Ariel Torres, filed a class-action lawsuit in federal court in Tampa, Florida, in 2020, arguing that Starbucks violated its obligations under ERISA to provide clear and complete COBRA notices.
Starbucks had sought to compel Lubin to arbitrate his claim, based on the arbitration agreement his wife had signed. However, the 11th Circuit ruled that Lubin’s claim was independent of his wife’s employment agreement and instead centered on his statutory right to receive accurate COBRA notices.
In the court’s opinion, Circuit Judge Barbara Lagoa wrote, “His claim has nothing to do with his wife’s employment agreement; rather, it centers on his statutory right to receive an adequate COBRA notice.” The decision clarifies that Lubin’s lawsuit is not derived from his wife’s employment contract, but rather from his own legal entitlement under federal law.
The ruling may have broader implications, potentially allowing other beneficiaries of corporate healthcare plans—such as spouses and dependents—to pursue similar claims independently, even if they were not part of the company’s workforce. The case also suggests that Starbucks could face a trial, though it remains uncertain whether the proposed class will include only beneficiaries who were not employed by the company.
In 2021, U.S. District Judge Charlene Honeywell had already ruled that Lubin’s case could proceed in court, as he was not bound by his wife’s arbitration agreement. Starbucks subsequently appealed the decision, arguing that Lubin’s claim was derivative of his wife’s employment relationship. The 11th Circuit, however, upheld the lower court’s ruling.
Legal Representation
For the Plaintiffs: Brandon Hill and Luis Cabassa of Wenzel Fenton Cabassa
For Starbucks: Sherril Colombo and Stefanie Mederos of Littler Mendelson
Case Reference: Torres v. Starbucks, 11th U.S. Circuit Court of Appeals, No. 21-11215
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