Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA)

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In Einkorn v. UMortgage, No. CV 25-2546, 2025 WL 3023412 (E.D. Pa. Oct. 29, 2025), the court held that plaintiff did not allege a “sexual harassment dispute” within the meaning of the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act, 9 U.S.C. §§ 401-402 (EFAA), such that the arbitration agreement she signed precluded…

Read More Non-Sexual Conduct Was Not “Sexual Harassment”; Arbitration Agreement Enforced
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In Twedell v. Senior Living Management Group, LLC, No. 6:25-CV-03214-MDH, 2025 WL 2988461 (W.D. Mo. Oct. 23, 2025), the court denied defendant’s motion to dismiss plaintiff’s claim for sexual harassment under Title VII of Civil Rights Act of 1964, and, upon applying the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021…

Read More Sexual Harassment Sufficiently Alleged; Motion to Compel Arbitration Denied
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In Smith v. Meta Platforms, Inc., 24 Civ. 4633 (JPC), 2025 WL 2782484 (S.D.N.Y. Sept. 30, 2025), the court held that a party invoking the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA) must actually allege facts that constitute sexual harassment. Here, the plaintiff did not: To determine whether this…

Read More Non-Sexual Gender Discrimination Did Not Trigger EFAA’s Arbitration Bar
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In Kelly v. Rosenberg & Estis, P.C. et al, 25-cv-4776 (CM), 2025 WL 2709157 (S.D.N.Y. Sept. 23, 2025), the court, inter alia, held that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021  (EFAA) applied to plaintiff’s entire case – which included her allegations of sexual harassment – and thus denied…

Read More Sexual Harassment Claim Made Out Under NYCHRL; EFAA Applied to Entire Case; Motion to Compel Arbitration Denied
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In Smith v. Boehringer Ingelheim Pharmaceuticals, LLC, 2025 WL 2403042 (D.Conn. Aug. 19, 2025), the court granted the defendant’s motion to compel arbitration of plaintiff’s sex-based hostile work environment claim under Title VII of Civil Rights Act of 1964. Specifically, the court held that plaintiff’s claims did not implicate the protections of the Ending of…

Read More Sex-Based Hostile Work Environment Not Plausibly Alleged, EFAA Did Not Apply, Arbitration Compelled
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In Lambert et al v. New Start Capital LLC et al, 1:24-cv-8055-GHW, 2025 WL 2295254 (S.D.N.Y. August 7, 2025), the court addressed a novel legal questions regarding the relatively new Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act (EFAA). In sum, one plaintiff – Lambert, a Black woman – alleges that she was…

Read More SDNY Interprets the EFAA to Apply to Sexual Harassment & Related Wage-and-Hour Claims, But Not to Third Plaintiff’s Claims Unrelated to Sexual Harassment Claims
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In Parks v. Nordson Medical of NH Inc., 2025 WL 2177177 (E.D.Tenn. July 31, 2025), the court held that plaintiff’s allegations did not plausibly state a claim for sexual harassment, and therefore that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 did not apply. From the decision: A court determines…

Read More Sexual Harassment Insufficiently Alleged; “Vulgar” Conduct Not Actionable
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In Thomas v. Poo Bah Enterprises, Inc., d/b/a Rick’s Cabaret Chicago, No. 25-cv-77, 2025 WL 2084159 (N.D.Ill. July 24, 2025), the court explained and clarified the pleading standard is contemplated by the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 in the context of a sexual harassment dispute. Here, plaintiff –…

Read More Court Adopts NY Federal Court’s Interpretation of EFAA in Retaliation/Sexual Harassment Case
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In Bulic v. Celebrity Cruises, Inc., No. 25-21231-CIV-ALTONAGA/Reid, 2025 WL 1783865 (S.D.Fla. June 27, 2025), the court denied defendant’s motion to compel arbitration, based on its interpretation of the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act (EFAA). The court summarized the facts as follows: This case arises from an alleged incident of nonconsensual…

Read More Court Denies Motion to Compel Claims Arising From Alleged Cruise Ship Sexual Assault; Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act Applied
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In Brazzano v. Thompson Hine LLP et al, 24-CV-01420 (ALC)(KHP), 2025 WL 96311 (S.D.N.Y. March 31, 2025), the court, inter alia, denied the defendants’ motion to compel arbitration of plaintiff’s sexual harassment claim under the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA). Specifically, the court held that plaintiff plausibly…

Read More Sexual Harassment Claims Plausibly Alleged; Motion to Compel Arbitration Denied Under Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021
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