Singh v. Meetup LLC

Background

Prerna Singh brought claims against Meetup LLC and David Siegel under Title VII, the Family and Medical Leave Act, the New York State Human Rights Law, and the New York City Human Rights Law. Her claims included sex discrimination, sexual harassment and hostile work environment, retaliation, interference with leave rights, and aiding and abetting alleged violations. Singh alleged that Siegel credited male employees with her accomplishments, ignored or claimed her contributions, assigned projects to male employees, interrupted her in meetings, questioned whether pregnancy and maternity leave would affect her commitment to work, and terminated her while she was on maternity leave.

As a condition of working at Meetup, Singh entered into a mandatory predispute arbitration agreement with Meetup. The defendants moved to compel arbitration and stay the case under the Federal Arbitration Act. In the alternative, they sought partial dismissal under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal for failure to state a legally sufficient claim. Singh did not challenge the validity of the arbitration agreement itself. Instead, she argued that the Ending Forced Arbitration Act allowed her to avoid arbitration because her claims included sexual-harassment allegations.

Legal Issue

The Ending Forced Arbitration Act generally prevents enforcement of a predispute arbitration agreement, at the election of the person alleging the conduct, in a case relating to a sexual-harassment dispute. The court applied a plausibility standard at this stage, meaning Singh had to allege facts that could reasonably support a sexual-harassment claim under the applicable law, rather than merely label the conduct sexual harassment.

The court examined the New York City Human Rights Law first because it provides the most lenient applicable standard. It distinguished sexual harassment from the broader category of gender discrimination. The court relied on the alleged conduct, rather than Singh’s labels that she experienced a hostile work environment or harassment. It concluded that the allegations plausibly described gender discrimination, but did not describe the unwelcome sexual or gender-based verbal or physical behavior that the court understood the New York City law to cover as sexual harassment. The court also held that the allegations failed under the New York State Human Rights Law because conduct that did not meet the New York City law’s plausibility threshold could not meet the plausibility threshold under the state law.

Ruling

The court held that the Ending Forced Arbitration Act was not triggered because Singh had not plausibly alleged a sexual-harassment dispute under either the New York City Human Rights Law or the New York State Human Rights Law. As a result, her claims were subject to the arbitration agreement.

Judge Oetken granted the defendants’ motion to compel arbitration and stay the case. He denied the defendants’ motion to dismiss the complaint in part without prejudice to renewal if the stay is lifted. The court stayed the case pending arbitration and directed the Clerk of Court to close the relevant motions and mark the case as stayed.