Hamrit v. Citigroup Global Markets, Inc.
- John Cronan
- 1:22-cv-10443
- U.S. District Court · Southern District of New York
- 3
Hamrit v. Citigroup Global Markets, Inc.: Judge Cronan denied Hamrit’s motion to stay arbitration while he pursued an interlocutory appeal.
Houssam Eddine Hamrit and the defendants, who remain required to begin arbitration before the Financial Industry Regulatory Authority and report whether it has begun.
What happened
In Hamrit v. Citigroup Global Markets, Inc., Houssam Eddine Hamrit, representing himself, asked the court to pause an order requiring the parties to begin arbitration before the Financial Industry Regulatory Authority. He sought the pause while pursuing an interlocutory appeal.
The court found no sufficient reason to pause arbitration. It explained that the Federal Arbitration Act does not allow an immediate appeal of an order compelling arbitration, so Hamrit had not shown a likely chance of success. The court also found that the other stay factors did not support pausing arbitration.
Judge John P. Cronan denied the motion for a stay. The parties remain required to begin arbitration and to file a joint status letter stating whether arbitration has begun.
The detailed version
- Hamrit v. Citigroup Global Markets, Inc. · No. 1:22-cv-10443
- John Cronan
- May 12, 2025
Background
On May 7, 2025, Houssam Eddine Hamrit, proceeding without a lawyer, filed a pre-motion letter asking for permission to move to stay, or pause, the Court’s April 22, 2025 order. That order required the parties to commence arbitration before the Financial Industry Regulatory Authority within sixty days of the date of the Court’s findings of fact and conclusions of law. Hamrit sought a stay so he could pursue an interlocutory appeal of several decisions in the case. The parties agreed that the Court could decide the request without additional briefing, so the Court treated the letter as a motion for a stay.
Legal standard
The Court considered four factors: whether Hamrit was likely to succeed on the merits of his appeal, whether he would suffer irreparable harm without a stay, whether a stay would substantially injure the other parties, and where the public interest lay. The Court also interpreted Hamrit’s filing liberally because he was representing himself.
Court’s analysis
The Court concluded that Hamrit had not shown a likelihood of success. Under the Federal Arbitration Act, an order granting a motion to compel arbitration is not immediately appealable. The Court therefore found no apparent basis for the Second Circuit to exercise appellate jurisdiction over Hamrit’s second interlocutory appeal.
The Court also found no irreparable harm sufficient to justify a stay. It explained that Congress chose, through the Federal Arbitration Act, to favor arbitration and to move arbitrable disputes from court into arbitration quickly. In the Court’s view, granting a stay would effectively create appellate rights that Congress had expressly withheld. The Court further concluded that the other parties would be harmed by delaying the arbitration agreement’s enforcement and that the public interest also favored proceeding with arbitration.
Disposition
Judge John P. Cronan denied Hamrit’s motion for a stay. The parties remained ordered to commence arbitration before the Financial Industry Regulatory Authority under the April 22, 2025 order. They were also reminded to file a joint status letter by June 23, 2025, stating whether arbitration had begun. The Clerk was directed to close Docket Number 126.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.