Discrimination Claims Must Be Arbitrated Against Goldman Sachs, Court Rules

In Crawford v. The Goldman Sachs Group, Inc., et al.; Index No. 159731/2020 (Feb. 23, 2021), an employment discrimination/retaliation case, New York Supreme Court Justice Paul Goetz issued a (relatively terse) order granting defendants’ motion to compel arbitration, reasoning that “the claims fall within the scope of the arbitration clause and are not barred by CPLR 7515 as this dispute is governed by the [Federal Arbitration Act].” In support, the court cites recent Southern District of New York decisions Gilbert v. Indeed, Inc., 2021 WL 169111 (S.D.N.Y. January 19, 2021) and Latif v. Morgan Stanley & Co., 18-CV-11528, 2019 WL 2610985 (S.D.N.Y. June 26, 2019). (Notably, the court did not cite or discuss the applicability of the NY Supreme Court’s decision in Newton v. LMVH Moët Hennessy Louis Vuitton Inc., 2020 NY Slip Op 32290(U), 154178/2019 (NY Sup. Ct. NY Cty. July 10, 2020), which declined to compel arbitration of plaintiff’s sexual harassment claim, in light of CPLR 7515.)

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