Hamrit v. Citigroup Global Markets, Inc.
- John Cronan
- 1:22-cv-10443
- U.S. District Court · Southern District of New York
- 2
In Hamrit v. Citigroup, Judge Cronan certified Hamrit’s second interlocutory appeal as frivolous and required a report on FINRA arbitration.
Houssam Eddine Hamrit and Citigroup Global Markets, Inc., along with the other defendants identified in the case caption; the order also directs the parties to proceed with FINRA arbitration.
What happened
In Hamrit v. Citigroup, the court had previously ordered the parties to begin arbitration before the Financial Industry Regulatory Authority within 60 days and to file a status letter after arbitration ended. Houssam Eddine Hamrit, representing himself, filed a second immediate appeal challenging that decision and other rulings.
The court explained that an order requiring arbitration generally cannot be immediately appealed, and that the challenged evidentiary rulings also were not immediately appealable. Neither party had asked to pause the arbitration order.
Judge John P. Cronan certified Hamrit’s second appeal as frivolous and legally ineffective to remove the court’s authority over the case. The parties remained required to begin arbitration and were ordered to file a joint letter by June 23, 2025, stating whether arbitration had begun.
The detailed version
- Hamrit v. Citigroup Global Markets, Inc. · No. 1:22-cv-10443
- John Cronan
- May 1, 2025
Background
On April 22, 2025, the Court issued findings of fact and legal conclusions and granted Citigroup’s motion to require arbitration. The prior order directed the parties to begin arbitration before the Financial Industry Regulatory Authority within 60 days of that decision and to file a joint status letter within two weeks after arbitration was completed.
On April 30, 2025, Plaintiff Houssam Eddine Hamrit, representing himself, filed his second notice of an immediate appeal. The notice challenged several court rulings, including the April 22 decision. The opinion states that neither party had moved to pause the arbitration order.
Appeal and jurisdiction
The Court explained that an order denying a motion to require arbitration is immediately appealable under the Federal Arbitration Act. In contrast, an order granting such a motion generally is not immediately appealable under the Act, subject to limited exceptions that the Court found did not apply. The Court also relied on its December 10, 2024 order in concluding that the evidentiary rulings challenged by Hamrit were not immediately appealable.
Because there was no apparent basis for appellate jurisdiction, the Court concluded that Hamrit’s notice did not remove the Court’s authority to continue handling the case. The Court certified the second interlocutory appeal as frivolous and legally ineffective to divest the Court of jurisdiction.
Disposition
The Court reminded the parties that they remained obligated under the prior order to begin arbitration before the Financial Industry Regulatory Authority within the required 60-day period. It further ordered the parties to submit a joint status letter by June 23, 2025, stating whether arbitration had begun. This order did not revisit the merits of the underlying dispute or the prior decision requiring arbitration.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.