DiLorenzo v. J. Crew Group, LLC
- Rochon
- 1:21-cv-10768
- U.S. District Court · Southern District of New York
- 12
In DiLorenzo v. J. Crew, Judge Rochon confirmed Defendants’ arbitration award and dismissed DiLorenzo’s complaint with prejudice.
Maria DiLorenzo, whose arbitration award challenge was rejected and complaint was dismissed with prejudice; J. Crew Group, LLC, Michael Nicholson, and Libby Wadle, whose arbitration award was confirmed.
What happened
DiLorenzo sued J. Crew Group, LLC, Michael Nicholson, and Libby Wadle under employment and disability-related laws. The parties arbitrated her claims, and the arbitrator ruled for the Defendants on all claims, including those under the Family and Medical Leave Act, the Americans with Disabilities Act, and New York law.
The Defendants asked the court to confirm the arbitration award. DiLorenzo argued that the arbitrator had clearly disregarded the law in evaluating her leave, accommodation, and retaliation claims. The court rejected those arguments, explaining that its review of an arbitration award was very limited and that DiLorenzo had not shown a legally recognized reason to set the award aside.
Judge Jennifer L. Rochon granted the Defendants’ motion to confirm the award. The court dismissed DiLorenzo’s complaint with prejudice and closed the case.
The detailed version
- DiLorenzo v. J. Crew Group, LLC · No. 1:21-cv-10768
- Rochon
- Mar. 10, 2025
Background
Maria DiLorenzo served as J. Crew’s General Counsel until the company terminated her employment on November 30, 2021. She had experienced sudden hearing loss, received a cochlear implant, and took paid time off after surgery. She later sued J. Crew Group, LLC, Michael Nicholson, and Libby Wadle, asserting claims under the Family and Medical Leave Act, the New York State Human Rights Law, and the New York City Human Rights Law. In arbitration, she also asserted breach-of-contract and Americans with Disabilities Act claims.
The parties conducted discovery and a four-day arbitration hearing before Arbitrator John C. Lifland. On October 4, 2024, he ruled for the Defendants. He found no interference with DiLorenzo’s Family and Medical Leave Act rights, no disability-discrimination violation, no failure to provide a reasonable accommodation, and no retaliation. He also denied her request for attorneys’ fees and costs.
DiLorenzo’s Objections
The Defendants moved under the Federal Arbitration Act to confirm the award. DiLorenzo opposed the motion, arguing that the arbitrator had acted in “manifest disregard” of the law—a narrow ground for vacating an award when an arbitrator knowingly and deliberately refuses to apply clearly established law.
DiLorenzo challenged the arbitrator’s conclusions about notice of Family and Medical Leave Act leave, work-related communications during her paid time off, disability accommodations, and the standard applied to her retaliation claims. The court rejected each argument. It held that the arbitrator had identified and applied the relevant legal principles, provided more than a minimally adequate explanation, and reached conclusions supported by the record. The court also declined to reweigh the evidence.
Ruling
Judge Jennifer L. Rochon found no basis to vacate, modify, or correct the arbitration award. The court also found no indication that the award had been obtained through corruption, fraud, or other impropriety. Because the Federal Arbitration Act generally requires confirmation when no statutory ground for vacatur is shown, the court GRANTED the Defendants’ motion to confirm the Award. DiLorenzo’s Complaint was DISMISSED with prejudice, and the Clerk was directed to close the case.
Read the full 12-page opinion on CourtListener, the free public archive maintained by the Free Law Project.