James Earl Graves Jr.

An unsigned arbitration agreement was unenforceable when its unambiguous text required both parties' signatures for execution.

“‘We begin this analysis with the contract’s express language. Unless that language is ambiguous, we end it there too.’ Hi Tech, 2019 WL 1908171, at *2 (citation modified). The Agreement’s language is not ambiguous. Both parties’ signatures were required to execute a valid arbitration agreement, and that is where we end our inquiry.”

The Railway Labor Act did not preempt an age-discrimination claim based on rights independent of the collective-bargaining agreement.

“[T]he RLA’s mechanism for resolving minor disputes does not pre-empt causes of action to enforce rights that are independent of the CBA.”

Concurrent state and federal emissions requirements did not create preemption without an identified difference in stringency that undermined the federal standard.

“But requiring a facility to meet both federal and Texas BACT requirements does not thwart or undercut the federal requirement, and PACAN does not identify any ‘difference in stringency’ that would create a preemptive effect.”

Reviewing a labor ruling, Graves required the agency to grapple with evidence that pointed in the opposite direction from its chosen inference. A reasoned decision should distinguish truly comparable conduct and explain why contrary examples do not alter the result.

“But the Board must nevertheless consider ‘contradictory evidence or evidence from which conflicting inferences could be drawn.’”

In an employment-scope case, Graves treated mixed personal and work purposes as a jury question when the employee's varied duties could include the errand at issue. Summary-judgment proof should address the task's connection to regular duties rather than rely on a personal-favor label.

“Conduct may be within the course and scope of employment even if done in part to serve the purposes of the employee or a third person.”

Graves would not enforce a generic settlement release against later overtime claims when those claims were never discussed or developed during the earlier negotiations. A wage release should resolve a bona fide dispute over the actual compensation at issue, not merely use broad language about all employment claims.

“the absence of any mention or factual development of any claim of unpaid overtime compensation in the state court settlement negotiations precludes a finding that the release resulted from a bona fide dispute under Martin.”