The US IA Digest collects in one place important decisions on US international arbitration case law issued since January 1, 2016, compiled and organized into categories that are most relevant and useful to practitioners and other interested parties. The Digest will be updated on a rolling basis as new decisions are issued.
Newly Released Decisions
Robinson v. Virginia College, LLC, No. 19-11864 (11th Cir. Oct. 16, 2019)
Court of appeals affirmed district court’s order denying defendants’ motion to compel arbitration, finding that plaintiff’s claims – as a student and former employee of one defendant – against defendants resulting from the latter’s loss of college accreditation fell outside of plaintiff’s employment-related arbitration agreement. Court found that because plaintiff’s claims arose from his role as a student, rather than an employee, rendered the claims not arbitrable.
Doud v. Gold, No. 1:19-CV-06561-KPF (S.D.N.Y. Oct. 16, 2019)
Court granted petitioners’ motion for summary judgment on their unopposed petition to confirm an arbitration award, finding that (i) petitioners met the low standard of showing “a barely colorable justification for the arbitrator’s conclusion,” (ii) the grounds for the arbitral award were readily discernable from the contents of the award, and (iii) there were no grounds for setting aside or modifying the award.
Nicholas v. Wayfair Inc., No. 1:19-CV-01974-JBW-LB (E.D.N.Y. Oct. 16, 2019)
Court granted defendants’ motion to compel arbitration, finding that plaintiff agreed to arbitrate her claims when she acquiesced to defendants’ website terms and conditions. Court found that the arbitration agreement was not unconscionable when the website text clearly indicated that submission of plaintiff’s order would result in her agreement to the terms and conditions.
Cooper v. Adobe Systems Incorporated, No. 5:18-CV-06472-BLF (N.D. Cal. Oct. 11, 2019)
Court granted defendant’s motion to compel arbitration, finding that notwithstanding plaintiff’s challenges to the formation of the arbitration agreement, the parties agreed to arbitrate issues of arbitrability by incorporating the JAMS rules.
Buhannic v. Tradingscreen, Inc., No. 18-2274 (2d Cir. Oct. 11, 2019)
Court of appeals affirmed district court order confirming an arbitration award, finding meritless petitioner’s claims that the arbitral panel had improper connections with the respondents. Court additionally refused to consider documentary exhibits not presented to the district court, finding that no obvious injustice or extraordinary circumstance justified the consideration of new allegations and evidence.