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At Long Last, California District Court Permanently Enjoins Enforcement of AB 51

There are times when one would rather not be proven right. Nearly four years ago, a California district court invalidated AB 51, which sought to prohibit mandatory arbitration by, among other things, calling for criminal...more

10th Circuit Reverses Class Certification in Claimed Off-the-Clock Case

Court also holds that arbitrability questions must be resolved by the arbitrator - The 10th Circuit has decided two significant issues in an otherwise garden-variety off-the-clock case, one relating to arbitration and the...more

Supreme Court Holds That a Case Should Be Stayed Automatically When a Party Appeals a Decision Not To Arbitrate It

While several recent Supreme Court decisions have garnered significant headlines, the Court’s late June ruling in Coinbase, Inc. v. Bielski, (Case No. 22-15), likely flew under the radar for the national media outlets. For...more

Supreme Court Holds Prejudice Not Required for Waiver of Right to Arbitrate - But Does Little Else

In a much-anticipated opinion, the Supreme Court unanimously held that a party claiming waiver of the right to arbitrate need not show prejudice, in Morgan v. Sundance, Inc., Case No. 21-328 (May 23, 2022). While the holding...more

Divided Ninth Circuit Reinstates Part of California’s Anti-Arbitration Law

For many years, state and federal courts in California have opposed arbitration and have manufactured frameworks under which they become unenforceable despite the clear directives of the Federal Arbitration Act (FAA) and...more

Ohio District Court Rejects Multiple Challenges to Electronically Signed Arbitration Agreement

Following the United States Supreme Court’s decision three years ago in Epic Systems Corp. v. Lewis, courts have increasingly enforced arbitration agreements with class action waivers. We blogged about the Epic Systems...more

California District Court Releases Opinion Invalidating AB 51

Two Centuries of Federal Precedent Given Effect - We’ve blogged several times the ongoing saga involving AB 51, California’s attempt to prevent the mandatory arbitration of employment claims largely by sanctioning...more

District Court Temporarily Enjoins Enforcement of California’s AB 51 Anti-Arbitration Provision

A federal judge has issued a temporary restraining order halting the enforcement of Assembly Bill 51, California’s latest attempt to prevent arbitration of claims brought under the California Fair Employment and Housing Act....more

Ninth Circuit Reverses Itself And Finds That At Least Some ERISA Claims Can Be Compelled To Arbitration

But Do You Really Want To In All Cases? The Employee Retirement Income Security Act of 1974 (“ERISA”) was the largest statute ever passed by Congress at the time it was enacted and has only grown further since then. ...more

Illinois District Court Stays Conditional Certification Order Pending Appeal on Arbitrability Issues

More games of cat and mouse - Following the Supreme Court’s decision in Epic Systems Corp. v. Lewis, 138 S. Ct. 1632 (2018), plaintiffs have tried to come up with strategies to address the impact of arbitration agreements...more

Supreme Court Overturns "Wholly Groundless" Exception to Contractual Delegations of Arbitrability Decisions to Arbitrators

On Jan. 8, 2019, the U.S. Supreme Court issued a unanimous decision regarding an important procedural issue under the Federal Arbitration Act (FAA). In Henry Schein, Inc. v. Archer & White Sales, Inc., No. 17-1272, it held...more

Tenth Circuit Refers Au Pairs’ Class Claims to Arbitration

“Well, They Gave Me the Agreement in My Own Language, but I Still Didn’t Understand the English Version” doesn’t work. The Federal Arbitration Act will turn 100 in the next few years, but despite more than nine decades of...more

Eleventh Circuit Overturns Default Judgment for Failing to Pay Arbitrator’s Fee

With the Epic Systems case broadly supporting employers’ rights to use arbitration agreements with class waivers, what is now emerging is the result of the necessary trade-off....more

[Gasp!] Epic Systems Decision Applies to FLSA Claims

No shocking outcome here. In Gaffers v. Kelly Services, Inc., Case No. 16-2210 (6th Cir. Aug. 15, 2016), the Sixth Circuit held that the Supreme Court’s decision in Epic Systems v. Lewis, 138 S. Ct. 1632 (2018) applies to...more

Ninth Circuit Finds ERISA Fiduciary Duty Claims Not Arbitrable

But decision leaves open many questions . . . With the Supreme Court’s Epic Systems decision laying to rest many of the primary arguments used to avoid arbitration, case law continues to develop regarding how arbitration...more

Supreme Court Upholds Legality of Class Action Waivers in Arbitration Agreements in the Employment Context

The controversy surrounding the validity of employment arbitration agreements with class action waivers has been simmering at least since 2012. Now, with the Supreme Court’s decision in Epic Systems Corp. v. Lewis, we have an...more

Sixth Circuit Refuses to Uphold Collective Action Waiver Absent Arbitration

My working title for this blog was “collective action grab bag,” concerning the recent Sixth Circuit case in Killion v. KeHE Distributors, LLC, Case Nos. 12-3357/4340 (6th Cir. July 31, 2014). I went with the title that...more

California District Court Rejects Shotgun Attacks on Arbitration Agreements

Alright, we all know in the wake of Italian Colors, Concepcion, and now many other cases that the presumption of arbitrability isn’t just a doctrine to recite in the manner of saying grace before invalidating an agreement,...more

Eleventh Circuit Refuses to Enforce Post-Suit Arbitration Agreements Based upon Employer Misconduct

The British have a phrase “too clever by half” to describe complex schemes that ultimately won’t work. We all know from cases such as Concepcion, Stolt-Nielsen, Italian Colors, and their progeny that arbitration...more

Sixth Circuit Holds That Duty To Arbitrate Survives Expiration of Employment Contract, Requires Individual Arbitration

With the Supreme Court having issued a series of decisions overruling many of the roadblocks to the enforcement of arbitration agreements in the class context, we are now seeing more courts fill in the gaps as to whether and...more

California State and Federal Courts Renew Their Attacks On Arbitration Agreements

In 1991, Sega introduced the video character Sonic the Hedgehog. Sonic became insanely popular, spawning several generations of videogames that are still being designed and sold today, comic books, and even a short-lived...more

California District Court Compels Arbitration of Class and Collective Wage and Hour Claims

Dorothy Gale famously remarked upon finding herself in Oz “Toto, I’ve got a feeling we’re not in Kansas anymore.” Class action wage and hour plaintiffs on the west coast are now awakening to the fact that while they may still...more

California Appellate Court Orders Arbitration and Rules that Claims May Not Proceed On Behalf of a Class Plaintiff in Macy's OT...

A recent decision from a California court of appeals reflects a growing, if at times reluctant, acceptance by California courts of employment arbitration. In Outland v. Macy’s Department Stores, Inc., Case No. A133589 (Ct....more

The Debate Continues: Recent Eighth Circuit Decision Adds to the Growing Tension between Federal Courts and the NLRB Regarding the...

Much like a war where each side steadily amasses victories and defeats, the federal courts and the National Labor Relations Board (NLRB) continue to have diverging opinions on the enforceability of class action waivers in...more

Courts Continue to Wrestle With Arbitration Issues

Decades ago, Congress passed the Federal Arbitration Act to combat the hostility courts showed towards arbitration agreements. Since that time, the Supreme Court has repeatedly pronounced the public policy in favor of the...more

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