Motion to Compel Arbitration Granted

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In Carlton v. Nat’l Debt Relief LLC, No. 2:26-CV-00944 (WJM), 2026 WL 1430099 (D.N.J. May 21, 2026), the court, inter alia, granted defendant’s motion to compel arbitration, rejecting plaintiff’s claim that her sex discrimination, retaliation, and any related claims are exempt from mandatory arbitration by the Ending Forced Arbitration of Sexual Assault and Sexual Harassment…

Read More Arbitration of Sex Discrimination Claim Compelled; Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 Held Inapplicable
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In Hamlin v. 1 Tyger LLC, No. 659803/2025, 2026 WL 1365454 (N.Y. Sup. Ct. May 11, 2026), the court granted the defendant’s motion to compel arbitration of his employment discrimination claims. From the decision: CPLR § 7503(a) provides that a party may move for an order staying an action and compelling arbitration. If there is…

Read More Employment Discrimination Claims Subject to Arbitration, Court Rules
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In Waiguchu v. Morgan Stanley & Co. LLC, No. 1:25-CV-7443-GHW, 2026 WL 892069 (S.D.N.Y. Apr. 1, 2026), the court, inter alia, held that plaintiff did not plausibly plead conduct constituting sexual harassment for purposes of the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA). In reaching this conclusion, the court…

Read More Allegations of Differential Treatment Based on Sex Was Not “Sexual Harassment” Sufficient to Trigger the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021
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In Shaw v. Salesforce, Inc., No. 25-CV-01372-PAB-STV, 2026 WL 787990 (D. Colo. Mar. 20, 2026), the court, inter alia, rejected plaintiff’s contention that she was not required to arbitrate her hostile work environment claim, under the Ending Forced Arbitration Agreements Act (“EFAA”). After summarizing the black-letter law, the court applied it to the facts as…

Read More Hostile Work Environment Claim Must Be Arbitrated; EFAA Did Not Apply
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In Memmer v. United Wholesale Mortgage, No. 23-CV-10921, 2026 WL 561393, at *8 (E.D. Mich. Feb. 27, 2026), the court, inter alia, granted defendants’ motion to compel arbitration and to dismiss plaintiff’s complaint, finding that plaintiff’s claims did not trigger the application of the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of…

Read More Sexual Harassment Insufficiently Alleged; EFAA Inapplicable; Arbitration Compelled
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In Kutagula v. Matterport, Inc., No. 25-CV-05383-NC, 2026 WL 478343 (N.D. Cal. Feb. 19, 2026), the court, inter alia, granted defendant’s motion to compel arbitration, finding that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act (EFAA) did not apply. From the decision: Plaintiff’s allegations, while concerning if true and may describe sex…

Read More Allegations, While Concerning, Did Not Amount to Sexual Harassment Triggering EFAA Protection From Arbitration
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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 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 Mahn v. Lawrence N. Mullman et al, Index No. 952263/23, Case No. 2024–03039, 2025 WL 408690 (N.Y.A.D. 1 Dept. Feb. 6, 2025), the Appellate Division, First Department, affirmed a lower court’s determination that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA) did not invalidate the parties’ arbitration agreement.…

Read More Sexual Assault-Related Claims Subject to Arbitration and Not Barred by EFAA, Court Holds
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