Stafa v. Innovative Facility Services
- Rochon
- 1:23-cv-10509
- U.S. District Court · Southern District of New York
- 4
In Lule Stafa v. Innovative Facility Services, Judge Rochon denied reconsideration of arbitration, stayed the case, and ordered further steps.
Lule Stafa and Innovative Facility Services are affected directly: Stafa must pursue the claims against IFS through the agreement’s mediation or arbitration procedures rather than in court, and the case is stayed. The opinion also recounts that Stafa’s claims against Union 32B-J had previously been dismissed.
What happened
Lule Stafa v. Innovative Facility Services; Union 32B-J concerns Stafa’s discrimination claims against Innovative Facility Services and Union 32B-J. The court had previously dismissed the claims against the Union and ordered arbitration of the claims against Innovative Facility Services.
Stafa asked the court to reconsider ordering arbitration, arguing that she did not knowingly agree to it, was concerned about arbitration’s fairness, and wanted to pursue her federal claims in court. The court said the collective bargaining agreement covered her and that its arbitration provisions were enforceable even without her specific agreement to them.
Judge Rochon denied Stafa’s request for reconsideration because she did not identify a change in controlling law, new evidence, clear error, or manifest injustice. The court stayed the case, directed Stafa and Innovative Facility Services to discuss the next steps toward mediation or arbitration, and required a status letter by October 1, 2025.
The detailed version
- Stafa v. Innovative Facility Services · No. 1:23-cv-10509
- Rochon
- Sept. 2, 2025
Background
Lule Stafa filed the action while representing herself. She asserted discrimination claims against Innovative Facility Services (IFS) and Union 32B-J. In an earlier order, the court granted the Union’s motion to dismiss Stafa’s claims against the Union and granted IFS’s motion to compel arbitration of Stafa’s claims against IFS.
Stafa later asked the court to reconsider the decision compelling arbitration. IFS opposed the request. Stafa did not file a reply or a brief opposing IFS’s filing, and the deadlines had passed.
Court’s Analysis
The court explained that reconsideration of a nonfinal order is available only in limited circumstances, such as a change in controlling law, newly available evidence, or the need to correct a clear error or prevent manifest injustice. Reconsideration is not a way to relitigate old issues or obtain another hearing on the merits.
Stafa argued that she had not knowingly agreed to arbitration or given up her right to sue in court. The court rejected that argument. It held that a lack of awareness of an arbitration provision in a collective bargaining agreement does not make the provision invalid or unenforceable. The court stated that unions may negotiate agreements that waive covered employees’ rights to bring claims in court and found that Stafa was bound by the agreement because the Union had negotiated it on behalf of covered employees.
Stafa also raised concerns about arbitration’s fairness based on her past experience and emphasized the seriousness of her federal claims. The court said she had not presented evidence or precedent that it had previously overlooked and could not override a valid collective bargaining agreement merely because she preferred to pursue her claims in court.
Ruling and Case Status
Judge Jennifer L. Rochon denied Stafa’s request for reconsideration. The court did not add a prejudice qualifier to that denial. Because IFS represented that Stafa had not started arbitration, the court directed Stafa and IFS to meet and discuss the next steps toward mediation or arbitration under the collective bargaining agreement. They must file a status letter by October 1, 2025. The Clerk was directed to terminate the pending motion at Docket 44 and mark the case as stayed.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.