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Electronic Acknowledgment of Agreement to Arbitrate in Employee Handbook Binds Former Employee: Mustaphalli v Citigroup Global Mkts., Inc.

Posted in Arbitration, CPLR 3211, CPLR 7503, Employee Handbook, FINRA, Industry: financial services, Justice Kitzes, Orin R., Motion to Compel Arbitration, Motion to Dismiss, NYS Human Rights Law, Queens

In an August 9, 2011 decision by Justice Kitzes, the court granted defendant’s motion to compel arbitration. Plaintiff-employee brought a discrimination claim against defendant-bank under the NYS Human Rights Law. Defendant moved to compel arbitration under an arbitration provision in its employee handbook, which expressly covered “all employment disputes based on legally protected rights,” including claims “regarding employment discrimination.” Plaintiff opposed the motion, contending that the employee-related documents submitted by defendant were “illegible” or did not clearly set forth a mandatory arbitration policy. The court disagreed, finding that the documents submitted on defendant’s motion, as well as plaintiff’s electronic acknowledgment of them and the policy therein, “evidenced an objective manifestation of assent [to the agreement to arbitrate], rendering plaintiff’s subjective understanding unnecessary.”  

Mustaphalli v Citigroup Global Mkts., Inc., Sup Ct, Queens County, August 9, 2011, Kitzes, J., Index No. 2473/2011