Consumers' Byline was a multilevel marketing and sales company. Rhodes was a participant who allegedly lost $500 through participation in Consumers' Byline. Rhodes sued, alleging various violations of New York state law, securities laws and RICO. The agreement contained a both a mandatory arbitration clause and choice of law provision designating New York law as the choice of governing law. Consumers' Byline moved to stay or dismiss, citing the arbitration clause and federal arbitration law, which requires a stay of the action until arbitration may be had.

Full case and case summary also available online at: http://www.mlmlegal.com/legal-cases/Rhodes_v_ConsumersBylineInc.php