Justia Arbitration & Mediation Opinion Summaries

The Trustees of the New York State Nurses Association Pension Plan (the Trustees) and White Oak Global Advisors, LLC (White Oak) entered into an investment management agreement, which included an arbitration clause. The Trustees later brought several fiduciary duty claims against White Oak under the Employee Retirement Income Security Act (ERISA), which were resolved through arbitration. The arbitrator issued an award in favor of the Trustees, which the Trustees sought to confirm in the United States District Court for the Southern District of New York.White Oak appealed the confirmation, arguing that the district court lacked jurisdiction and that the court erroneously interpreted the award. The United States Court of Appeals for the Second Circuit affirmed the district court's jurisdiction, finding that the Trustees' petition to confirm the award was cognizable under ERISA § 502(a)(3). The court also affirmed the district court's interpretation of the award regarding the disgorgement of pre-award interest and the "Day One" fees. However, the court vacated and remanded the district court's confirmation of the disgorgement of White Oak's "profits," finding the award too ambiguous to enforce. The court also vacated and remanded the district court's order for White Oak to pay the Trustees' attorneys' fees and costs, finding the district court's findings insufficiently specific. View "Trustees of the NYSNAPP v. White Oak Glob. Adv." on Justia Law

Isabel Garcia, an employee of RAC Acceptance East, LLC (RAC), filed a lawsuit against RAC, Stoneledge Furniture LLC (Stoneledge), and Inderjit Singh, alleging ten claims related to sexual harassment. RAC, Stoneledge, and Singh sought to compel arbitration based on an arbitration agreement they claimed Garcia electronically signed during her employment onboarding process. Garcia denied signing the agreement and argued that RAC failed to prove she executed the agreement.The trial court denied the petitions to compel arbitration. It found that while RAC had initially shown an agreement to arbitrate by providing the agreement, Garcia's denial of signing the agreement shifted the burden back to RAC to prove by a preponderance of the evidence that her electronic signature was authentic. The court found that RAC failed to meet this burden as the declaration provided by RAC did not present sufficient details of the onboarding process to establish how Garcia must have signed the agreement. The court also found that the agreement did not have the appearance of an electronically signed document created in Taleo, the third-party electronic workforce management platform used by RAC.On appeal, the Court of Appeal of the State of California First Appellate District Division Three affirmed the trial court's decision. The appellate court found that the trial court did not err in deciding whether any agreement to arbitrate existed in the first place, rather than delegating that decision to an arbitrator. The appellate court also found that RAC failed to prove the existence of the arbitration agreement. The court concluded that RAC's evidence did not show that only Garcia could have placed the electronic signature on the arbitration agreement. The court also found that the trial court did not abuse its discretion in denying RAC’s request for an evidentiary hearing. View "Garcia v. Stoneledge Furniture LLC" on Justia Law

The case involves the interpretation of Section 3 of the Federal Arbitration Act (FAA), which outlines procedures for enforcing arbitration agreements in federal court. The petitioners, current and former delivery drivers for an on-demand delivery service operated by the respondents, filed a lawsuit alleging violations of federal and state employment laws. The respondents moved to compel arbitration and dismiss the suit. The petitioners agreed that their claims were arbitrable but argued that Section 3 of the FAA required the District Court to stay the action pending arbitration rather than dismissing it entirely. The District Court issued an order compelling arbitration and dismissed the case without prejudice. The Ninth Circuit affirmed the decision.The Supreme Court of the United States reversed the Ninth Circuit's decision. The Supreme Court held that when a district court finds that a lawsuit involves an arbitrable dispute and a party has requested a stay of the court proceeding pending arbitration, Section 3 of the FAA compels the court to issue a stay, and the court lacks discretion to dismiss the suit. The Court reasoned that the statutory text, structure, and purpose all point to this conclusion. The Court further explained that the FAA's structure and purpose confirm that a stay is required. The Court concluded that staying rather than dismissing a suit comports with the supervisory role that the FAA envisions for the courts. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Smith v. Spizzirri" on Justia Law

Jennifer D. Aldea-Tirado, an employee of PricewaterhouseCoopers LLP (PWC), filed a lawsuit against her employer alleging violations of Title VII of the Civil Rights Act, the Pregnancy Discrimination Act of 1978, and Puerto Rico law. Aldea-Tirado claimed she was subjected to adverse employment action due to her gender and pregnancy and was retaliated against for filing a complaint with the United States Equal Employment Opportunity Commission. PWC, however, argued that Aldea-Tirado's employment contract contained an arbitration clause and moved to compel arbitration.The United States District Court for the District of Puerto Rico granted PWC's motion to compel arbitration. The court determined that PWC had established the existence of a valid agreement between PWC and Aldea-Tirado to arbitrate her claims. The court also found that Aldea-Tirado had tacitly consented to the Agreement by continuing to work for PWC after having received the Agreement through both regular mail and email. Aldea-Tirado appealed this decision.The United States Court of Appeals for the First Circuit affirmed the lower court's decision. The appellate court found no merit in Aldea-Tirado's arguments that she did not receive the Agreement or that it was unconscionable to hold her to it. The court also rejected Aldea-Tirado's contention that she was not given "some minimal level of notice" that her continued employment would effect a waiver of her right to pursue her claims in a judicial forum. The court concluded that Aldea-Tirado failed to show that there was any non-speculative basis in the record from which a reasonable factfinder could determine that she did not receive the email to which the Agreement was attached. View "Aldea-Tirado v. PricewaterhouseCoopers, LLP" on Justia Law

Yuriria Diaz, a former employee of Macy's West Stores, Inc., filed a lawsuit under the California Private Attorneys General Act (PAGA) for alleged violations of California's labor code. Macy's appealed the district court's order compelling arbitration of all Diaz's claims. The United States Court of Appeals for the Ninth Circuit affirmed the district court's order compelling arbitration of Diaz's individual PAGA claims, but vacated the order to the extent it compels arbitration of her non-individual claims.Previously, the district court had compelled arbitration of all Diaz's claims, interpreting the arbitration agreement between Diaz and Macy's to include non-individual PAGA claims. The court denied Diaz's request for a stay and closed the case, stating there were no remaining claims before the court.The Ninth Circuit concluded that it had jurisdiction to review the district court's order as a final decision with respect to arbitration. The court found that at the time of contracting, the parties consented only to arbitration of individual claims relating to Diaz's own employment. The agreement's language was strongly indicative of an intent to exclude any amalgamation of employees’ claims—including non-individual PAGA claims—from arbitration.The court rejected Macy's request that the district court on remand be instructed to dismiss the non-individual claims because under a recent California Supreme Court decision, those claims cannot be dismissed. The court remanded with instruction to treat the non-arbitrable non-individual claims consistent with the California Supreme Court’s decision, anticipating that the parties will, per their agreement, request a stay with respect to those claims. View "Diaz v. Macy’s West Stores, Inc." on Justia Law

The case involves Ramon Dejesus Cedeno, an employee of Strategic Financial Solutions, LLC, and a participant in its Strategic Employee Stock Ownership Plan. Cedeno sued the company, its trustee Argent Trust Company, and other defendants under the Employee Retirement Income Security Act (ERISA), alleging that a transaction caused the Plan to incur substantial losses and that Argent breached fiduciary duties owed to Plan participants. The defendants moved to compel arbitration under the Federal Arbitration Act (FAA), pointing to a provision in the Plan’s governing document that required Plan participants to resolve any claims related to the Plan in arbitration.The United States District Court for the Southern District of New York denied the motion, reasoning that the agreement was unenforceable because it would prevent Cedeno from effectuating rights guaranteed by Congress through ERISA, namely, the plan-wide relief available under Section 502(a)(2) to enforce the rights established in ERISA Section 409(a).On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision. The court held that the arbitration provision is unenforceable because it would prevent Cedeno from pursuing the Plan-wide remedies Sections 409(a) and 502(a)(2) unequivocally provide. The court concluded that the entire arbitration provision is null and void due to a non-severability clause in the Plan. View "Cedeno v. Sasson" on Justia Law

The case involves Angel Mondragon, an employee of Sunrun Inc., who was required to sign an arbitration agreement as a condition of his employment. The agreement covered most disputes related to Mondragon’s employment but excluded claims brought under the Private Attorney General Act of 2004 (PAGA). After his employment ended, Mondragon filed a complaint asserting several causes of action under PAGA. Sunrun filed a motion to compel arbitration of Mondragon’s claims, which the trial court denied. Sunrun appealed the decision, arguing that the trial court erred in ruling on whether Mondragon’s claims were arbitrable.The Superior Court of Los Angeles County had previously denied Sunrun's motion to compel arbitration. The court ruled that it, not the arbitrator, should decide questions of arbitrability. The court also ruled that the arbitration agreement unambiguously excluded PAGA claims and did not differentiate between individual PAGA claims and PAGA claims brought on behalf of other employees.The Court of Appeal of the State of California Second Appellate District Division Seven affirmed the decision of the lower court. The court concluded that Mondragon, an unsophisticated party, did not delegate arbitrability decisions to the arbitrator. The court also concluded that the language of the arbitration agreement did not require Mondragon to arbitrate his individual PAGA claims. Therefore, the court affirmed the decision of the lower court. View "Mondragon v. Sunrun Inc." on Justia Law

In 2015, Joseph Semprini filed a lawsuit against his employer, Wedbush Securities, Inc., alleging 11 personal causes of action and seven class claims for alleged wage and hour violations. Semprini and Wedbush agreed that Semprini’s personal claims would be arbitrated, while the remaining claims would proceed in court. The class was certified in 2017, and the parties litigated Semprini’s class and Private Attorneys General Act (PAGA) claims in court over the next several years. In 2022, the U.S. Supreme Court ruled in Viking River Cruises, Inc. v. Moriana that an employer may enforce an employee’s agreement to arbitrate individual PAGA claims. Following this decision, Wedbush asked its workforce to sign arbitration agreements, and 24 class members, including the second named plaintiff, Bradley Swain, agreed to do so.The Superior Court of Orange County denied Wedbush’s motion to compel arbitration of the named plaintiffs’ individual PAGA claims and the claims of the 24 class members who signed arbitration agreements. The court found that Wedbush had waived its right to compel arbitration by entering into the 2015 stipulation.The Court of Appeal of the State of California Fourth Appellate District Division Three affirmed the lower court's decision. The court held that even if the Viking River decision or the 2022 arbitration agreements gave Wedbush a new right to move to compel certain claims to arbitration, Wedbush waited too long to make its motion, particularly in light of the looming trial date. The court found that Wedbush had waived its right to compel arbitration by waiting nine months after the Viking River decision and five to six months after select class members signed the new arbitration agreements to file its motion to compel arbitration. View "Semprini v. Wedbush Securities Inc." on Justia Law

The case revolves around Dycom Industries, Inc. ("Dycom") and its predecessor, Midtown Express, LLC ("Midtown"), a cable contractor that installed, serviced, and disconnected telecommunications cables for Time Warner Cable Company customers in New York City and Bergen County, New Jersey. Midtown had collective bargaining agreements with Local Union No. 3 of the International Brotherhood of Electrical Workers, which required contributions to the Pension, Hospitalization & Benefit Plan of the Electrical Industry (the "Fund"), a multiemployer pension plan under ERISA. In 2016, Midtown ceased operations and contributions to the Fund, leading the Fund to assess withdrawal liability against Midtown and its successor, Dycom, under ERISA.Midtown demanded arbitration, arguing that its employees were performing work in the building and construction industry, and thus it was exempt from withdrawal liability under ERISA. The arbitrator determined that Midtown did not qualify for the exemption, concluding that Midtown's employees did not perform work in the building and construction industry. Dycom then filed a lawsuit to vacate the arbitrator's award, and the Fund filed a cross-motion to confirm the award. The district court adopted the magistrate judge's report and recommendation, denied Dycom's motion to vacate the award, and granted the Fund's cross-motion to confirm the award.The United States Court of Appeals for the Second Circuit affirmed the district court's judgment. The court concluded that the cable installation services at issue did not involve work in the "building and construction industry" under ERISA, and thus Dycom was not exempt from withdrawal liability. The court found that the arbitrator correctly determined that the work performed by Midtown was not work within the building and construction industry under ERISA, and thus the exemption did not apply. View "Dycom Indus., Inc. v. Pension, Hosp'n & Benefit Plan of the Elec. Indus." on Justia Law

Neal Bissonnette and Tyler Wojnarowski, distributors for Flowers Foods, Inc., a major producer and marketer of baked goods, sued the company for alleged violations of state and federal wage laws. Flowers Foods moved to compel arbitration under the Federal Arbitration Act (FAA). The key issue was whether the exemption from coverage under the FAA for any "class of workers engaged in foreign or interstate commerce" is limited to workers whose employers are in the transportation industry.The District Court dismissed the case in favor of arbitration, stating that for Bissonnette and Wojnarowski to be exempt from the FAA, they must be "transportation workers." The court concluded that their broader scope of responsibility under the Distributor Agreements belied the claim that they were primarily truck drivers. The Second Circuit affirmed the District Court's decision on the alternative ground that Bissonnette and Wojnarowski "are in the bakery industry." According to the Second Circuit, §1 of the FAA exempts only "workers involved in the transportation industries."The Supreme Court of the United States disagreed with the Second Circuit's interpretation. The Court held that a transportation worker does not need to work for a company in the transportation industry to be exempt under §1 of the FAA. The Court emphasized that the relevant question is what the worker does for the employer, not what the employer does generally. The Court vacated the judgment of the Second Circuit and remanded the case for further proceedings consistent with its opinion. The Court did not express an opinion on any alternative grounds in favor of arbitration raised below. View "Bissonnette v. LePage Bakeries Park St., LLC" on Justia Law