Summary
The court granted Tracy Price’s petition for attorneys’ fees and costs incurred in post-arbitration proceedings in an employment-discrimination action under the Americans with Disabilities Act and the Pennsylvania Human Relations Act. The court held that the complaint established federal-question jurisdiction, that the Federal Arbitration Act did not itself provide an independent jurisdictional basis, and that Price was a prevailing party entitled to recover fees and costs under the PHRA. The court awarded $21,565.00 in attorneys’ fees and $402.00 in costs.
Topics
Practice areas
Questions Presented
- Whether the court retained federal-question and supplemental jurisdiction to award attorneys' fees and costs for post-arbitration proceedings.
- Whether plaintiff was a prevailing party entitled to attorneys' fees under the Pennsylvania Human Relations Act.
- Whether plaintiff could recover the $402 filing fee as a necessary and taxable cost under the Pennsylvania Human Relations Act and Federal Rule of Civil Procedure 54(d)(1).
Holdings
- The Federal Arbitration Act does not itself create federal subject matter jurisdiction; an independent jurisdictional basis must exist.
- Plaintiff was a prevailing party under the PHRA and was entitled to recover reasonable attorneys' fees for post-arbitration proceedings necessary to secure enduring judicial relief.
- The court awarded plaintiff $21,565.00 in attorneys' fees and $402.00 in costs incurred in the post-arbitration proceedings.
Key quotations
“But the FAA does not create federal subject matter jurisdiction for these filings.” (at 2)
“The jurisdiction of the court was established with the federal question presented in the complaint.” (at 4)
“The court's jurisdiction extends to an award of fees to the prevailing party for matters necessary to securing enduring judicial relief that are exclusively before this court and beyond the scope of the underlying arbitration proceeding.” (at 4)
“Plaintiff is awarded an additional amount of $21,565.00 in attorneys fees and additional costs in the amount of $402.00.” (at 1)
Factual background
Plaintiff's complaint asserted an employment-discrimination claim under the Americans with Disabilities Act and a parallel claim under the Pennsylvania Human Relations Act. The parties' dispute proceeded to arbitration, after which plaintiff sought confirmation of the award and defendants sought vacatur in federal court. The court entered judgment in plaintiff's favor and plaintiff sought recovery of fees and the filing cost incurred in the post-arbitration proceedings.
Procedural history
Plaintiff brought claims under the Americans with Disabilities Act and the Pennsylvania Human Relations Act. The court compelled arbitration under the Federal Arbitration Act and stayed the case while retaining jurisdiction. After the arbitrator issued a final award, plaintiff sought confirmation and defendants sought vacatur; the court entered an opinion and order on September 18, 2025, followed by final judgment under Federal Rule of Civil Procedure 58. Plaintiff then petitioned for attorneys' fees and costs incurred after arbitration.