Arizona District Court Underscores the Importance of Robust E-Signature Authentication for Enforcing Arbitration Agreements

In Parrish v. Vulcan Materials Company, 2025 WL 2710407 (D. Ariz. Sep. 23, 2025), the U.S. District Court for the District of Arizona granted an employer’s motion to compel arbitration, holding that a valid arbitration agreement was formed through the employee’s electronic onboarding and that the employer’s security procedures and records sufficiently authenticated the electronic signature. 

The plaintiff in Parrish filed a putative class action against his employer, alleging wage-and-hour violations. The employer moved to compel arbitration based on an agreement the plaintiff signed electronically through an online system at both the application and onboarding stage. The plaintiff denied ever signing the agreement, claiming that he could not recall reviewing or signing an arbitration agreement and could not find the email Vulcan claims he would have received if he had been asked to sign one through the online system.

The district court cited to Arizona law recognizing that a “secure” electronic signature—in other words, a signature that is unique to the user, capable of verification, under the user’s sole control, and linked to the record—may demonstrate assent even if the signer later does not recall signing. In holding for the employer and finding the agreement was valid, the court credited multiple, mutually reinforcing data points demonstrating formation and authenticity. 

First, the agreement bore the plaintiff’s affirmative assent and personal identifiers—name, Social Security number, date of birth, and ZIP code—and captured the IP address used to sign. Second, the employer used a third-party online system for applications, which required candidates to create a unique username and password that the employer could not retrieve, and which automatically recorded dates, times, task progression, and IP addresses. Third, the third-party company records showed a timeline including the creation of the arbitration agreement task; completion of the arbitration agreement; immediate creation of I‑9 and beneficiary tasks; and completion of those forms later the same evening. Fourth, the employer established by declaration its practices of disqualifying applicants who would not agree to later sign arbitration agreements and rescinding offers if new hires failed to sign during onboarding. 

Based on this record, the court held that the employer met its burden to prove a valid arbitration agreement by a preponderance of the evidence and compelled arbitration. Parrish highlights how a well-documented and secure e-onboarding system can bolster the enforceability of arbitration agreements if challenged. Employers with arbitration agreements should consult experienced counsel to assess whether their e‑signature workflows meet Arizona’s standards for authentication and security.