Narrative Opinion Summary
The case involves female employees of a jewelry company who alleged gender discrimination and sought to compel arbitration under the RESOLVE agreement. The Arbitrator certified a class of about 70,000 employees for Title VII claims, which the company challenged, arguing the Arbitrator exceeded her authority. Initially, the court supported the Arbitrator's decision, but a Supreme Court ruling prompted a reversal, questioning the Arbitrator's power to bind absent class members to class arbitration. The Second Circuit vacated the court's ruling, remanding the issue to determine the Arbitrator's authority concerning non-parties. Ultimately, the court concluded the Arbitrator could not bind absent members who did not opt-in, leading to vacating the class certification award. The court held that the Federal Arbitration Act allows vacating an award if the Arbitrator oversteps her powers, emphasizing that the RESOLVE agreement did not authorize class procedures without explicit consent from all affected parties. The case underscores the complexities of arbitration agreements and class certification, particularly regarding non-consenting parties and the interpretation of such agreements under state and federal law.
Legal Issues Addressed
Arbitration Authority under RESOLVE Agreementsubscribe to see similar legal issues
Application: The court examined whether the Arbitrator could bind absent class members to class procedures under the RESOLVE agreement.
Reasoning: The court found that the Arbitrator could not bind non-parties to class action procedures where it had been previously established that the arbitration agreement did not permit such procedures.
Class Arbitration and Consent of Absent Memberssubscribe to see similar legal issues
Application: The court ruled on the requirement for absent class members to opt-in to confer authority on the arbitrator for class arbitration.
Reasoning: The Arbitrator lacked the authority to allow class procedures for absent members who did not opt in, leading to the decision to vacate the February 2, 2015 Award regarding the certification of such a class.
Contractual Interpretation and Class Arbitrationsubscribe to see similar legal issues
Application: The court addressed the interpretation of the RESOLVE agreement in relation to class arbitration procedures, and the implications of Ohio law on such interpretation.
Reasoning: The agreements do not explicitly mention class arbitration procedures. However, the Arbitrator ruled that class procedures were permissible, reasoning that the agreements did not prohibit them and were considered contracts of adhesion under Ohio law.
Federal Arbitration Act and Arbitrator Authoritysubscribe to see similar legal issues
Application: The court considered the extent of an arbitrator's powers under the Federal Arbitration Act to bind non-consenting parties to arbitration awards.
Reasoning: Under the Federal Arbitration Act, a district court may vacate an arbitration award if the arbitrator exceeded her powers, focusing on whether the arbitrator had the authority under the parties' agreement to address a specific issue.