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Non-Signatories Arbitration Agreements

Miller Canfield

United States Court of Appeals Enforces Arbitration Agreement Against Third-Party Non-Signatories

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Arbitration agreements often seem straightforward—until they unexpectedly bind parties who never signed them. The United States Court of Appeals for the Eleventh Circuit’s recent decision in Various Insurers v. General...more

Ervin Cohen & Jessup LLP

Equitable Estoppel Can Be Invoked By a Non-Signatory Joint Employer to Compel Arbitration

Tell me if you have heard this one before: ten companies are sued by a former employee as “joint employers”, even though the employee technically worked for, and signed a binding arbitration agreement with, only one of them....more

DarrowEverett LLP

LLC's Failure to Execute Operating Agreement Opens Legal Trapdoor

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While entity distinctness is a bedrock principle of corporate law, it may often appear redundant and unnecessary for a limited liability company (“LLC”) to sign its own operating agreement. That was likely the thinking of the...more

CDF Labor Law LLP

Good News for Employers: California Enforces Arbitration Agreement In Favor of Non-Signatory Related Entities

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Frequently, employment arbitration agreements are written with the intent to apply to future disputes between an employee, the employer and the employer’s parent and sister companies....more

Seyfarth Shaw LLP

Arbitration Agreement Enforceable By Non-Signatory Alleged Joint-Employers

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Employees who sign an arbitration agreement with one company cannot avoid arbitration with related defendant-companies by arguing they were not parties to the agreement. The California Court of Appeal held that claims against...more

Lewitt Hackman

Beyond the Contract: Non-Signatories to an Arbitration Agreement Can Compel Arbitration

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Departing from the ruling in Soltero v. Precise Distribution earlier this year, the California Court of Appeal in the Second District in Gonzalez v. Nowhere Beverly Hills LLC, created a split of authority regarding an alleged...more

Foley & Lardner LLP

Non-Signatory Bound to an Agreement’s Arbitration Clause

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In Ice Rak, LLC v. Rita’s Franchise Co., LLC, the Court enforced an arbitration agreement against a non-signatory of the same agreement because courts will consider the significance of the franchisees’ actions and...more

Lewitt Hackman

Franchisee 101: Frozen Out of Court

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A Florida district court granted a motion to stay court proceedings pending arbitration between a franchisor and a third-party, non-signatory to a franchise agreement, containing an arbitration clause....more

Snell & Wilmer

Nevada Recognizes the Ability of Non-Signatories to Compel Arbitration

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In a recent case of first impression in Nevada, the Nevada Supreme Court found en banc that a nonsignatory to an arbitration agreement may compel another nonsignatory to arbitrate...more

McGlinchey Stafford

Can a Non-Signatory Be Compelled to Arbitrate? - McGlinchey Commercial Law Bulletin - January 26, 2024

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Conditions Precedent- In this appeal, the Eighth Appellate Court affirmed in part the trial court’s determination that Defendant breached its contract with Plaintiff disagreeing with Defendant-appellant that Plaintiff failed...more

Carlton Fields

Broker Obtains Preliminary Injunction Enjoining FINRA Arbitration Initiated by Non-Signatories to Arbitration Agreement

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Interactive Brokers LLC filed an action in the Southern District of New York seeking preliminary and permanent injunctions against an arbitration proceeding initiated by a group of non-signatories to an agreement between...more

Carlton Fields

Court Confirms Arbitration Award Against Non-Signatory Intervening Party in Arbitration

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Paychex Inc. had entered into an agreement to provide a company, Dan-Gulf Shipping Inc., with payroll-related services. The agreement contained an arbitration clause governed by the rules of the American Arbitration...more

JAMS

Arbitrating With Nonsignatories: Celebrity Edition

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Kim Kardashian and Tiger Woods are international celebrities, and they have something else in common. Both have been involved in disputes regarding arbitrating with nonsignatories to an arbitration agreement. The idea of...more

Carlton Fields

Sixth Circuit Holds That District Court Erred by Not Analyzing Whether Non-Signatory Consented to Arbitration

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The Sixth Circuit Court of Appeals recently vacated and remanded an order concluding that a party was not bound by an arbitration award after concluding that the district court failed to consider whether that party may have...more

Farrell Fritz, P.C.

Binding Nonsignatories to Arbitration Agreements

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Closely-held business owners often hope to avoid the costs and delays of litigation by including arbitration provisions in their partnership, shareholder, and operating agreements. Things can get tricky, though, when...more

Carlton Fields

SDNY Rules Non-Signatories to Agreement May Compel Signatory to Arbitrate Issues of Arbitrability

Carlton Fields on

Plaintiffs, the Republic of Kazakhstan and Outrider Management LLC, filed suit in New York state court claiming the defendants conspired to obtain a fraudulent international arbitral award against them of nearly $500 million....more

Carlton Fields

Second Circuit Affirms Denial of Motions to Compel Arbitration in Suit Against Trump Corp. and Trump Family

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The Second Circuit recently affirmed the denial of motions to compel arbitration filed by, inter alia, the Trump Corp. and a nonparty from whom the plaintiffs sought discovery....more

Carlton Fields

West Virginia Federal Court Refuses to Force Non-Signatory to Participate in Arbitration

Carlton Fields on

Mountain Valley Pipeline LLC (MVP) contracted with U.S. Trinity Energy Services LLC for the construction and installation of the Mountain Valley Pipeline across property in Greenbrier County, West Virginia. Trinity...more

Farrell Fritz, P.C.

When Faced with Questions of Arbitrability, the Suffolk County Commercial Division Passes the Ball to the Arbitrator

Farrell Fritz, P.C. on

In a recent Commercial Division case, Justice Elizabeth H. Emerson was asked to determine whether certain parties were bound by an arbitration clause and whether that arbitration clause applied to a particular controversy—two...more

Morrison & Foerster LLP - Left Coast Appeals

This Week at the Ninth: Drug Tests and Foreign Arbitration

This week, the Ninth Circuit considers a challenge to the constitutionality of the FAA’s regulations governing drug and alcohol testing for air-carrier employees, and it wrestles with difficult choice-of-law questions...more

Jackson Lewis P.C.

Ninth Circuit Upholds Arbitration For Non-Signatory Defendant

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California law is not typically seen as amiable to compelling employees to arbitrate their claims. However, in Franklin v. Community Regional Medical Center, ___ F.3d___(9th Cir. 2021), the Ninth Circuit panel upheld a motion...more

Rumberger | Kirk

Kratos Investments vs. ABS Healthcare: Third DCA Confirms Enforceability of Arbitration Provision by Non-Signatory

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When it comes to arbitration provisions, you may get more than you bargained for. The Third District Court of Appeals recently confirmed that by signing an arbitration provision, the signatory may be forced to arbitrate by a...more

Womble Bond Dickinson

Court Grants Motion to Compel Arbitration of Claims of Non-Signatory to Contract

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In Shelton v. Comcast Corp., No. 20-1763, 2021 U.S. Dist. LEXIS 10790 (E.D. Pa. Jan. 21, 2021), the U.S. District Court for the Eastern District of Pennsylvania granted Comcast’s motion to compel arbitration under the terms...more

Mintz - Arbitration, Mediation, ADR...

Lessons From Above: SCOTUS Declines to Review a Class Arbitrability Case (the Issue Had Been Delegated to an Arbitrator)

In its restraint, SCOTUS has shown us the mischief that arbitrators may do if parties are lax in setting boundaries in their agreement to arbitrate. By declining to grant certiorari regarding the Second Circuit’s most recent...more

Snell & Wilmer

From the U.S. Supreme Court: The New York Convention Does Not Bar Non-Signatories to an Arbitration Agreement From Compelling...

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The U.S. Supreme Court recently addressed whether a non-signatory’s attempt to compel arbitration under an international arbitration agreement using domestic doctrines of equitable estoppel is barred by the Convention on the...more

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