Saiti v. Century Management

Background

Isa Saiti, proceeding without a lawyer, sued Century Management under Title VII of the Civil Rights Act of 1964 and the New York State Human Rights Law. Saiti alleged that he worked as a doorman for Century Management, that the company required employees to obtain COVID-19 vaccinations, and that he requested a religious exemption based on his Muslim faith. He submitted a signed religious-exemption affidavit and an excerpt of the Quran. According to the complaint, Century Management denied the request and terminated him for failing to provide proof of vaccination.

Century Management filed an unopposed motion to dismiss for lack of subject-matter jurisdiction and failure to state a claim. The court had given Saiti additional time to respond and warned that the motion would be treated as unopposed if he did not respond. Saiti never filed a response. The court explained that it still had to decide whether the complaint was legally sufficient rather than dismissing solely because Saiti failed to respond.

Court’s Analysis

The court focused on claim preclusion, also called res judicata. This rule prevents a party from bringing claims that were already decided, or could have been decided, in an earlier proceeding when the earlier proceeding involved the same parties or legally represented interests and the same underlying facts.

The court found that an arbitration involving Saiti’s union was a decision on the merits. After hearing two days of testimony, the arbitrator found no direct evidence of discrimination and no connection between the employer’s actions and an inference that its stated reason was pretextual.

The court also found the required relationship between the parties. Local 32BJ brought the arbitration on Saiti’s behalf, and Saiti was a union member while the union served as his exclusive collective-bargaining representative. The court therefore found that Saiti’s interests were represented by the union. It also found that Century Management was legally connected to the employer identified in the arbitration materials, which was listed as “315 East 70th Apartment Corp. c/o Century Management Services.”

Finally, the court found that the arbitration and the lawsuit arose from the same facts: the denial of Saiti’s religious-exemption request and his later termination. Because the claims had already been adjudicated in arbitration, or could have been raised there, the court held that claim preclusion barred the lawsuit. The court noted that Century Management’s separate argument about a mandatory arbitration clause was generally more appropriate for a request to pause the case for arbitration, but the arbitration had already occurred, so the court focused on claim preclusion.

Ruling

Judge J. Paul Oetken granted Century Management’s motion to dismiss. The court directed the Clerk of Court to enter judgment dismissing Saiti’s claims and to close the case. The opinion does not state that the dismissal was with or without prejudice.

Effect

The ruling ended Saiti’s federal court employment-discrimination action based on the court’s conclusion that the prior arbitration barred relitigation of those claims.