Sanders v. Citibank
- 3:25-cv-09362
- U.S. District Court · Northern District of California
- 3
In Jeston Sanders v. Citibank, the court compelled arbitration, stayed proceedings, and denied Sanders’s amendment request as moot.
Jeston Sanders’s claims against Citibank, N.A. must proceed in arbitration rather than in the federal case, which is stayed. Sanders’s request to file an amended complaint was denied as moot, and both parties must provide periodic status reports.
What happened
Jeston Sanders brought a credit-related lawsuit in small claims court, and Citibank, N.A. moved the case to federal court. Sanders did not dispute entering a card agreement with an arbitration provision, but argued that the provision excluded his case because it began in small claims court.
The court rejected that argument because the exclusion applied only while the matter stayed in small claims court. The court also found that Citibank did not give up its right to arbitration by moving the case to federal court, answering the lawsuit, or opposing Sanders’s earlier motions.
The court, whose judge was not named in the opinion, granted Citibank’s motion to compel arbitration and stayed the case. It denied Sanders’s request to file an amended complaint as moot and required the parties to submit regular joint updates about the arbitration.
The detailed version
- Sanders v. Citibank · No. 3:25-cv-09362
- Mar. 12, 2026
Background
Jeston Sanders filed a credit-related lawsuit against Citibank, N.A. in small claims court. Citibank removed the case to the U.S. District Court for the Northern District of California. The court had previously denied Sanders’s motion to send the case back to state court. Citibank then moved to compel arbitration and stay the federal case while arbitration proceeded.
Arbitration agreement
Under the Federal Arbitration Act, the court considered whether the parties had a valid arbitration agreement and whether that agreement covered the dispute. Citibank submitted evidence that Sanders entered into a card agreement containing an arbitration provision. Sanders did not dispute entering into the agreement or the arbitration provision.
Sanders argued that the provision excluded his claims because they were filed in small claims court. The provision stated that individual claims filed in small claims court were not subject to arbitration “as long as the matter stays in small claims court.” The court interpreted that qualification to mean that the exclusion ended once the case was removed to federal court. Because this case had been removed, the court held that the arbitration provision covered Sanders’s claims.
Waiver
The court also rejected Sanders’s argument that Citibank waived, or gave up, its right to seek arbitration. The court explained that waiver requires knowledge of the right to arbitration and intentional conduct inconsistent with that right. It held that Citibank did not waive arbitration by removing the case, answering while asserting arbitration as a defense, or opposing Sanders’s motions to strike that defense and to remand the case. The court also reasoned that Citibank could not seek arbitration while the case remained in small claims court, so its failure to seek arbitration earlier did not show that it abandoned the right.
Ruling and next steps
The court granted Citibank’s motion to compel arbitration and stayed the case pending arbitration. The parties must file a joint status report every 120 days, beginning on the date of the order, and another report within 14 days after the arbitration proceedings end. The court denied Sanders’s motion for leave to file an amended complaint as moot because the claims would be subject to arbitration under either the existing complaint or the proposed amended complaint.
The opinion identifies the decision-maker only as a United States District Judge; it does not provide the judge’s name.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.