Employees who sign arbitration agreements during onboarding may be sent to arbitration.
Aetaekayakalua Shimoyama Riley v. Samsung Electronics Home Appliances
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Employees who sign arbitration agreements during onboarding may be sent to arbitration.
Why it matters
In Riley v. Samsung Electronics Home Appliances America, LLC, a federal district court in South Carolina is working through whether a signed arbitration agreement from the employee onboarding process is enforceable against a pro se plaintiff who brought multiple employment discrimination claims. The court had already rejected the plaintiff's arguments based on public policy, unconscionability, and waiver, but sent the case back to a magistrate judge to examine the narrower question of whether a valid arbitration agreement was actually formed. The opinion excerpt covers the procedural steps taken on that contract formation question, including limited discovery and a motion for summary judgment filed by the defendant.
Who it affects
This ruling most directly affects the plaintiff employee and Samsung, but it also has practical relevance for other employees who sign arbitration agreements during onboarding and later bring workplace discrimination claims. Employers who use such agreements in South Carolina may also be affected by how courts in this district examine whether those agreements were validly formed.
What happens next
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Decision issued Aug 27, 2026
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- Decision issued Aug 27, 2026
- Possible rehearingParties can ask the same court to reconsider.
- Possible appeal to the circuit court
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Aug 27, 2026
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DEEPER READ
The central question before the court is whether a binding arbitration agreement was formed when the plaintiff, Aetaekayakalua Shimoyama Riley, signed documents during new-employee onboarding at a Samsung appliance plant in South Carolina. The plaintiff was hired in late December 2024 and fired roughly two months later, after which he filed pro se claims for discrimination and retaliation under the ADA, FMLA, Title VII, the Rehabilitation Act, and South Carolina state law. Samsung moved to send those claims to arbitration based on a mutual Mediation and Arbitration Agreement the plaintiff signed during onboarding. The court had previously adopted a magistrate judge's recommendation rejecting the plaintiff's arguments that statutory discrimination claims cannot be arbitrated, that the agreement was unconscionable, and that Samsung had waived its right to arbitrate. However, the district court noticed that the magistrate judge had not addressed whether the parties actually reached a meeting of the minds when forming the agreement. Out of special caution for the plaintiff's pro se status, the court sent the matter back to the magistrate judge to examine only that contract formation question. On remand, the court allowed limited discovery on the formation issue. The defendant provided the plaintiff with a copy of the arbitration agreement and other relevant documents, and took a limited deposition of the plaintiff. The plaintiff also sought broader discovery, asking for the complete onboarding package, but the magistrate judge found that request untimely and beyond the scope of the discovery order, because the plaintiff had not shown that other onboarding documents were relevant to whether an arbitration agreement was formed. The defendant then filed a motion for summary judgment specifically on the contract formation question. The magistrate judge issued a report and recommendation on that motion, but the full content of that recommendation is not completely reproduced in the available source text. The court is now reviewing that report before issuing a final ruling on whether the arbitration agreement is valid and whether the plaintiff's claims must proceed in arbitration rather than in federal court. No dissent is reflected in the available source text, as this is a district court order rather than a multi-judge appellate decision. The outcome of the contract formation question will determine whether the plaintiff's discrimination claims are heard by an arbitrator or remain in federal court.
CITATION AND RECORD
Record source: CourtListener
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA ANDERSON/GREENWOOD DIVISION Aetaekayakalua Shimoyama Riley, ) Civil Action No. 8:25-cv-8398-TMC ) Plaintiff, ) ) ORDER v. ) ) Samsung Electronics Home Appliances ) America, LLC, ) ) Defendant. ) ) Background Defendant operates an appliance manufacturing facility in Newberry County, South Carolina, manufacturing washing machine components and assembling washing machines. On or around December 23, 2024, Defendant hired Plaintiff to work as a Process Innovation Technician at its Newberry plant. (ECF No. 17 at 4). During the new-employee onboarding process, Plaintiff signed Defendant’s Alternative Dispute Resolution Program, which included a mutual Mediation and Arbitration Agreement. (ECF No. 28-2) (“Arbitration Agreement”). Plaintiff worked at Defendant’s plant for slightly over two months. (ECF No. 17 at 4). His employment was terminated on or about March 5, 2025. Id. Subsequently, Plaintiff, proceeding pro se, brought this action against Defendant, asserting numerous employment-related discrimination claims, including claims for discrimination and retaliation under the Americans with Disabilities Act (“ADA”), 42 U.S.C. §§ 12101 et seq.; the Family and Medical Leave Act (“FMLA”), 29 U.S.C. § 2601 et seq.; Title VII of the Civil Rights Act of 1964, as amended (“Title VII”), 42 U.S.C. § 2000e et seq.; and Sections 503 and 504 of the Rehabilitation Act. (ECF No. 17). Plaintiff also asserts a state law claim for constructive discharge and for violations of South Carolina Human Affairs Law (“SCHAL”) S.C. Code Ann. § 1-13-10 et seq. (ECF No. 17 at 3). In accordance with 28 U.S.C. § 636(b)(1)(A) and Local Civil Rule 73.02(B)(2)(e), (g) (D.S.C.), this matter was referred automatically to a United States Magistrate Judge for all pretrial proceedings. Early in the litigation, Defendant filed a motion to dismiss and compel arbitration of Plaintiff’s claims based on the Arbitration Agreement signed by Plaintiff. Plaintiff opposed the motion, arguing that statutory discrimination claims such as those asserted in this case cannot be subject to compulsory arbitration; that the arbitration provision is unconscionable—and thus unenforceable; that Defendant waived its ability to arbitrate her claims. The magistrate judge issued a report rejecting these arguments and recommending that the court grant Defendant’s motion to compel arbitration of Plaintiff’s claims and stay this action. (ECF No. 37). On January 8, 2026, this court issued an order adopting the magistrate judge’s conclusions rejecting Plaintiff’s arguments based on public policy, unconscionability and waiver and determining that, if Plaintiff’s claims are ultimately sent to arbitration, the case must be stayed rather than dismissed. (ECF No. 48). However, the court noted that the magistrate judge did not address the issue of whether there was mutual assent or meeting of the minds as to arbitration— i.e., whether an underlying arbitration agreement was formed in the first instance. Id. at 7. Although Plaintiff failed to clearly articulate this position in his filings before the magistrate judge, the court, “[o]ut of an abundance of caution for Plaintiff’s pro se status,” was “forced to conclude that the best course is to squarely address Plaintiff’s contract formation argument.” Id. at 8. Therefore, the court recommitted the matter to the magistrate judge for analysis of the single issue of contract formation. Id. Recommitted on Contract Formation Issue After the action was recommitted on the issue of contract formation, Plaintiff filed a motion for limited discovery. (ECF No. 50). Plaintiff sought “the production of the complete onboarding documents allegedly forming the basis of Defendant’s arbitration argument”; “the complete job- fair packet provided to Plaintiff” even though Plaintiff acknowledged “arbitration was not presented or explained at the job fair”; and “the complete training/onboarding packet executed by Plaintiff, including all attachments, addenda, arbitration provisions, medical disclosure forms, and signature or initial pages.” (ECF No. 50 at 4–5). In response, Defendant consented to Plaintiff’s request to the extent it was related to the formation and existence of an agreement to submit any disputes to arbitration. (ECF No. 51 at 4). Additionally, Defendant requested leave to conduct a limited deposition of Plaintiff regarding these issues. The magistrate judge issued an order granting Plaintiff’s motion in part, directing Defendant “to provide Plaintiff with any documents presented to him or signed by him regarding or evidencing his agreement to submit any and all disputes to final and binding arbitration,” and allowing Defendant to conduct a limited deposition of Plaintiff. (ECF No. 52). The parties were ordered to complete such limited discovery by March 25, 2026, and to file any motions regarding the single issue of contract formation by April 15, 2026. According to Defendant, it provided Plaintiff with a copy of the Arbitration Agreement on March 9, 20206, and confirmed it had produced all documents responsive to the magistrate judge’s directive by March 11, 2026. (ECF No. 55 at 3). Defense counsel also took Plaintiff’s limited deposition on March 23, 2026. Id. On April 15, 2026, Defendant filed the instant motion for summary judgment on the issue of contract formation. (ECF No. 55). Plaintiff filed a response in opposition, (ECF Nos. 59 and 60), to which Defendant filed a reply, (ECF No. 62). Plaintiff also subsequently filed a “motion to compel” the “full onboarding package,” arguing that the materials produced pursuant to the magistrate judge’s order are insufficient for a determination of the issue of contract formation. (ECF No. 61). Defendant opposed the motion to compel on the grounds that it was untimely and sought documents that exceed the scope of the magistrate judge’s order at ECF 52: “Plaintiff has made no showing whatsoever that any of the documents in the “complete onboarding packet,” besides the Arbitration Agreement, make any reference to, or evidence, Plaintiff’s agreement to arbitrate. To the contrary, he merely alleges, without any support or authority [that the entire onboarding packet is necessary] . . .” (ECF No. 64 at 6). Order and Report and Recommendation On July 29, 2026, the magistrate judge issued the Order and Report and Recommendation (the “Report”) that is presently before the court. (ECF No. 78). With respect to Plaintiff’s non- dispositive motion to compel, (ECF No. 61), the magistrate judge concluded the motion was untimely; the motion sought discovery beyond the scope of Magistrate Judge Hodges order directing limited discovery regarding documents presented to or signed by Plaintiff relating to arbitration; and, “to the extent Plaintiff argues or believes the Arbitration Agreement is incomplete
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