What HR's HRIS records must show to make e-signatures stick in court
A Pennsylvania appeals court just handed employers a roadmap - and a warning - for defending click-through arbitration agreements.
On June 9, 2026, the Superior Court of Pennsylvania vacated a Philadelphia trial court ruling that had refused to enforce arbitration agreements against a former Prime Communications employee. The appellate panel sent the case back for further proceedings on whether the employee, David Levin, electronically signed either of two Mutual Agreements to Arbitrate that his employer put in front of him through its HR information system.
Levin had sued Prime and AT&T over his employment agreement. The employers asked the court to send the dispute to arbitration, pointing to a 2019 agreement issued when Prime acquired Levin's prior employer, Spring, and a 2022 agreement Levin was prompted to acknowledge through the company's HRIS.
Levin's defense was simple. He said he did not recall signing any arbitration agreement and had never signed one. Neither version in the record carried his handwritten signature. The 2022 document had a blank "Employee Signature" line. The 2019 document had no signature page at all.
To close the gap, Prime submitted a sworn declaration from its associate director of human resources, Shanesta Jacobs. Jacobs walked through how the HRIS worked. Each employee had a unique username and password. When Levin logged in, she said, he was shown the arbitration agreement and a screen prompt telling him that clicking "I agree" - for the 2019 agreement - or "Acknowledge Policy" - for the 2022 agreement - would constitute his signature and bind him to the contract. She attached a Policy Acknowledgment History showing Levin's name, an "e-signature" entry, and a timestamp of 4:01:01 p.m. on February 13, 2019. A separate record showed an acknowledgment dated January 7, 2022.
The trial court was unmoved. It said the agreements required Levin's signature, neither carried one, and the policy reports did not contain his e-signature or the "I agree" box Jacobs had described. It also refused to consider Jacobs's declaration, calling it "extrinsic evidence" and ruling that the validity of the contract had to be judged from the contract itself.
The Superior Court disagreed on both points.
On the evidence question, the panel said Pennsylvania civil procedure lets trial courts consider affidavits and other outside evidence when deciding whether an arbitration agreement was ever formed. The four-corners rule applies to interpreting a contract's terms, not to deciding whether the contract exists.
On electronic signatures, the panel turned to Pennsylvania's Uniform Electronic Transactions Act. That statute treats an electronic signature as any electronic symbol or process attached to a record and executed with intent to sign. A click-through counts, the court said, if it is attributable to the person and carried out with the intent to do something legally binding. The screen prompts Jacobs described - one stating that an electronic signature would bind Levin to the 2019 agreement, the other stating that clicking the acknowledgment box constituted a signature and created an enforceable contract - were enough that a reasonable person in Levin's position would have understood the click as a signature.
The panel noted Levin offered nothing of his own to contest Jacobs's account. He filed no affidavit. He attached no exhibits. He rested on his pleading.
Even so, the panel did not order arbitration. Because Jacobs's declaration came from the party seeking arbitration, it could not resolve the factual question on its own. The case returns to the trial court to make findings on whether Levin actually performed the click-throughs, and if so, whether his dispute falls within the scope of the agreements.
For HR leaders, the takeaway is less about the result than about what Prime did, and didn't, have in its file. The employer kept timestamped HRIS records tying Levin's username to specific clicks. It produced a declaration from an HR officer who could explain the system end to end. It tied each click to a screen-level explanation of legal consequence. What it did not have was a captured copy of the agreement showing a visible e-signature mark, which is why the dispute landed in front of an appeals court in the first place.
HR functions running arbitration programs through an HRIS should be stress-testing their own records against the same standard. That means screen prompts that clearly state the click constitutes a signature. It means audit trails linking the user account to the specific document version acknowledged, with a timestamp. And it means having someone in HR who can credibly walk a court through how the system works.
