Christine Martindale v. Digital Trends LLC d/b/a Growth Lab

Summary

The court granted Digital Trends LLC’s motion to compel arbitration and stay all proceedings in Christine Martindale’s employment-discrimination action. The court held that the arbitrator must decide whether claims asserted in Martindale’s second amended EEOC charge fall within the arbitration agreement, while claims covered by the agreement’s carveout were non-arbitrable. Because the arbitrable claims predominated and overlapped with the non-arbitrable claims, the court stayed the entire case pending resolution of arbitrability.

Holdings

1. Because the employment agreement expressly provided that questions regarding arbitrability would be decided by the arbitrator, and the parties disputed whether the carveout covered the Second Amended Charge claims, the question of arbitrability was delegated to the arbitrator.
2. Claims asserted in the Second Amended Charge must be stayed pending resolution of their arbitrability by the arbitrator.
3. The court exercised its discretion to stay the non-arbitrable claims because the arbitrable claims predominated and the non-arbitrable claims were closely intertwined with the arbitrable claims.

Questions Presented

1. Whether the arbitrability of claims asserted in Martindale's Second Amended EEOC Charge was delegated to an arbitrator under the employment agreement.
2. Whether the claims asserted in the Second Amended Charge had to be stayed under section 3 of the Federal Arbitration Act.
3. Whether the court should exercise its discretion to stay the non-arbitrable claims asserted in the First Amended Charge.

Disposition

other