Doctor's Associates, LLC v. Tripathi

Summary

The Second Circuit affirmed an injunction barring franchisees from pursuing state-court claims against a Subway franchisor and its non-signatory agent, holding that the district court had jurisdiction under the All Writs Act and the relitigation exception to the Anti-Injunction Act. The court found that the arbitration agreement clearly and unmistakably delegated issues of arbitrability, including the enforceability of a clause precluding claims against agents, to the arbitrator under AAA Commercial Rules. The effective-vindication doctrine did not apply because the franchisees could still vindicate their state-law rights in arbitration against the franchisor.

Holdings

1. The district court had jurisdiction under the All Writs Act and the relitigation exception to the Anti-Injunction Act because the district court's delegation ruling that gateway issues of arbitrability were for the arbitrator would be contradicted by a state court reaching the merits, and the relitigation exception does not require identical parties.
2. The arbitration agreement clearly and unmistakably delegated the issue of enforceability of the preclusion provision to the arbitrator in the first instance because the parties incorporated the AAA Commercial Rules, which empower arbitrators to decide objections to the scope, validity, or arbitrability of the agreement.

Questions Presented

1. Whether the district court had jurisdiction under the Anti-Injunction Act to enjoin the California state-court action with respect to claims against Patel, who was not a party to the federal action.
2. Whether the arbitration provision precluding claims against Patel is enforceable.

Disposition

affirmed