Washington v. American Arbitration Association
- Louis Stanton
- 1:25-cv-00440
- U.S. District Court · Southern District of New York
- 7
In Washington v. American Arbitration Association, Judge Stanton denied recusal as moot and dismissed Washington’s complaint without prejudice for violating a prior filing injunction.
Marcus Washington’s action against the named defendants was dismissed without prejudice. The order did not resolve the merits of any possible claims against The Whitby Hotel, which was not named as a defendant.
What happened
In Washington v. American Arbitration Association, Marcus Washington sued the American Arbitration Association, federal judges, the Equal Employment Opportunity Commission, and other people and entities. He filed the case without a lawyer and without first obtaining permission required by an earlier court order.
Washington’s complaint described disputes involving employment discrimination claims, arbitration, and the handling of his earlier lawsuits. He also discussed claims involving The Whitby Hotel, but he did not name that hotel as a defendant in this case.
Judge Louis L. Stanton denied Washington’s request to disqualify Chief Judge Swain as moot because the case had been reassigned. Judge Stanton dismissed Washington’s complaint without prejudice because he did not comply with the earlier filing injunction by seeking permission before filing.
The detailed version
- Washington v. American Arbitration Association · No. 1:25-cv-00440
- Louis Stanton
- July 9, 2025
Background
Marcus Washington, appearing without a lawyer, sued the American Arbitration Association; federal district judges Peter Kevin Castel and Eric Komitee; the estate of Robert P. Patterson; the Equal Employment Opportunity Commission and several of its employees and officers; and other named defendants. The case was transferred from the Eastern District of New York to the Southern District of New York.
The complaint concerned Washington’s earlier employment-discrimination disputes, arbitration proceedings, and actions involving federal judges, the American Arbitration Association, and the Equal Employment Opportunity Commission. Washington also described the termination of his employment with The Whitby Hotel and related claims. He did not name The Whitby Hotel as a defendant in this action. He sought declaratory, injunctive, equitable, and monetary relief, including damages from the American Arbitration Association, relief against the judges and agency employees, and a stay of arbitration involving his claims against The Whitby Hotel.
The court explained that Washington was subject to a filing injunction issued in a prior related proceeding, No. 10-CV-09647 (S.D.N.Y.). That injunction barred him from filing an action in federal district court arising from or relating to that proceeding or its arbitration against specified people and entities—including the American Arbitration Association, its employees and agents, arbitrators, and federal judges and court personnel—without first obtaining written permission from the court. The opinion states that Washington knew of the injunction but did not seek permission before filing this action.
Rulings
Washington moved to disqualify Chief Judge Swain from presiding over the case. Because the matter had been reassigned to Judge Stanton, the court denied that motion as moot.
The court dismissed Washington’s complaint without prejudice because he failed to comply with the filing injunction by seeking leave before filing the action. The court did not decide the merits of Washington’s claims. It also stated that the dismissal did not prevent Washington from pursuing any claims concerning The Whitby Hotel, which was not a defendant here. Any request to reopen a separate closed case had to be made in that separate matter. The Clerk was directed to terminate all pending motions, and judgment was entered.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.