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Tennessee Supreme Court Permits Consideration of Extrinsic Evidence in Dispute About Capacity to Enter Power of Attorney Used to...

The Supreme Court of Tennessee has approved a trial court’s consideration of extrinsic evidence regarding whether an individual with Down syndrome had the capacity to execute a durable power of attorney that his brother used...more

NLRB Stacks Deck in Favor of Employees: Employers Must Play Cards Defensively or Go Bust

The National Labor Relations Board has made a series of employee-friendly moves over the past few months that have significant adverse implications for employers, including those in the insurance and securities industries....more

Munich Re Prevails in Alabama Reinsurance Dispute

A federal court recently agreed with Munich Re that it was not obligated to reimburse an insurer for losses and fees the insurer incurred in litigation with its professional liability carrier regarding a bad faith claim...more

Nevada Supreme Court Reverses Order Denying Motion to Compel Arbitration

The Nevada Supreme Court recently reversed the denial of a motion to compel arbitration, explaining that the plaintiff’s arguments that the contract at issue was illegal were not a valid basis to deny arbitration because...more

Southern District of New York Dismisses Petition to Confirm $145M Foreign Arbitration Award for Lack of Personal Jurisdiction

The Southern District of New York recently dismissed a petition to confirm a $145 million arbitration award rendered in Hong Kong based on lack of personal jurisdiction....more

Third Circuit Affirms Judgment Allowing Creditors of Venezuela Who Obtained Arbitration Awards to Attach U.S. Assets of...

The Third Circuit Court of Appeals has again allowed creditors of Venezuela to attach assets belonging to Venezuela’s national oil company to satisfy arbitration awards against Venezuela. The Third Circuit rejected...more

First Circuit Holds That New York Convention Preempts Puerto Rican Law

The First Circuit Court of Appeals has held that the New York Convention applies to an insurance arbitration dispute between a Puerto Rican company and Lloyd’s of London and that the convention preempts a Puerto Rican law...more

NLRB Ratchets Up Campaign Against Noncompete Agreements

On May 30, 2023, the National Labor Relations Board’s general counsel, Jennifer Abruzzo, issued an enforcement memorandum asserting that most noncompete provisions in employment contracts and severance agreements violate the...more

First Circuit Provides Additional Guidance on FAA’s Transportation Worker Exception

The First Circuit Court of Appeals has followed up on its recent jurisprudence outlining the standards for the Federal Arbitration Act’s “transportation worker exception,” as we previously posted, by applying its recently...more

Second Circuit Clarifies Standards for Applying Presumption in Favor of Arbitration

The Second Circuit Court of Appeals recently clarified its process for determining whether a court can apply a presumption of arbitrability. The court noted that its traditional process for making that determination does not...more

Expect Focus - Volume II, May 2023

For broker-dealers distributing and selling variable annuities, examinations will test for compliance with Reg BI and FINRA Rule 2330 because both standards apply to variable annuity sales. Firms distributing and selling...more

En Banc Eleventh Circuit Overrules Prior Interpretation of New York Convention

The Eleventh Circuit Court of Appeals has overruled long-standing precedent and joined the Second, Third, Fifth, and Seventh Circuits to hold that the grounds for vacatur of an arbitral award are set out in domestic law...more

First Circuit Weighs in on FAA’s Transportation Worker Exception

The First Circuit Court of Appeals recently clarified the standards for invoking the “transportation worker” exception to the Federal Arbitration Act. The court noted that fact-finding on that exception should focus on the...more

Companies See Big Rise in Labor & Employment Class Actions and Defense Spending

The 2023 Carlton Fields Class Action Survey has revealed a significant increase in the number of labor and employment class action lawsuits and the amount companies are spending to defend those lawsuits. That is sobering news...more

Biden Administration Seeks to Prohibit Blanket Ban on Transgender Student Athletes

Transgender athletes’ participation in school sports has been an area of focus for governing bodies like the National Collegiate Athletic Association and the Connecticut Interscholastic Athletic Conference, as well as state...more

Fifth Circuit Refuses to Vacate Arbitration Award, Holds That Party’s Arguments Merely Ask for Merits Review

The Fifth Circuit Court of Appeals recently rejected a claim that an arbitration award should be vacated by holding that the challenging party’s arguments improperly asked the court to review the merits of the arbitration...more

Arbitrability Is Question for Court in Case Alleging Fraud Regarding Agreement Between Parties

The Court of Appeals of Maryland recently held that the question of arbitrability was for a court, not an arbitrator, to decide where the plaintiffs alleged that the defendants had fraudulently induced them to enter...more

Tenth Circuit Affirms Refusal to Vacate Confirmation Despite Foreign Court’s Annulment of Underlying Arbitration Award

The Tenth Circuit recently affirmed a district court’s decision not to vacate a confirmation award even though the underlying arbitration award had been annulled by a Bolivian court following the confirmation. The Tenth...more

Supreme Court of Wyoming Confirms Arbitration Award

The Supreme Court of Wyoming recently rejected claims by a party that had largely prevailed in arbitration, but asserted that it should have received its fees, and that the arbitrator incorrectly decided several issues....more

Fifth Circuit Affirms Judgment Confirming Award Despite Concluding Lower Courts Erred by Not Considering Claim That Dispute Could...

The Fifth Circuit affirmed judgments confirming an arbitration award despite concluding that the lower courts should have considered one of the party’s claims that a dispute decided by the arbitrator was beyond the scope of...more

Expect Focus - Volume I, January 2023

More than 25 years have elapsed since the SEC adopted Exchange Act Rule 17a-4(f) governing electronic recordkeeping by broker-dealers. In an effort to update the rule to reflect “technology neutral” concepts, the SEC adopted...more

Decision Against McDonald’s Includes Important Lessons For Employers About Sexual Harassment in the Workplace

A decision by the Delaware Court of Chancery allowing shareholders to sue McDonald’s over an alleged “toxic culture” of sexual harassment and misconduct at McDonald’s provides a stark reminder that employers must actually...more

D.C. Circuit Affirms Denial of Stay of Enforcement of International Arbitration Award

The D.C. Circuit affirmed the denial of a stay regarding the enforcement of an international arbitration award under the New York Convention. In 2010, the country of Moldova allegedly failed to pay energy bills to...more

Sixth Circuit Affirms Judgment Compelling Arbitration in Kroger/Union Dispute

The Sixth Circuit recently rejected a challenge to a Rule 12(c) judgment compelling arbitration in a dispute between a Kroger subsidiary and a union that represented its employees. Kroger Limited Partnership I (KLPI),...more

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