Employment Newsletter - April 2013: Second Circuit Upholds Arbitration Agreement Blocking Title VII Class Claims


In a victory for employers, the Second Circuit issued a decision enforcing an arbitration agreement and denying plaintiff’s request to pursue class-wide litigation of her Title VII claims in court in Parisi v. Goldman, Sachs & Co., No. 11–5229, 2013 WL 1149751 (2d. Cir. March 21, 2013). This decision provides proactive employers within the Second Circuit’s boundaries with a tool to potentially decrease certain kinds of class-action litigation through carefully drafted arbitration agreements.

The Case: Parisi v. Goldman, Sachs & Co. -

Plaintiff, a former managing director at Goldman Sachs, had signed an arbitration agreement as part of a promotion in 2008. After the termination of her employment, plaintiff and two former colleagues filed a complaint in federal court alleging gender discrimination under Title VII on a class-wide basis. When Goldman Sachs moved to compel individual arbitration, plaintiff argued that the agreement was unenforceable and that a judicial forum was appropriate because she and her former colleagues were alleging “a continuing pattern and practice of discrimination based on sex,” in violation of Title VII. Plaintiff’s arbitration agreement was silent on the ability to bring class claims.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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