Pappas v. AMN Healthcare Services
- Jon Tigar
- 4:24-cv-01426
- U.S. District Court · Northern District of California
- 2
Counsel of record per CourtListener. Firm names are approximate.
In Pappas v. AMN Healthcare Services, Judge Tiga denied amendment, compelled individual arbitration, dismissed class allegations, and stayed the litigation.
The five named travel-nurse plaintiffs, the proposed class and collective claims, and AMN Healthcare Services and the other defendants. The named plaintiffs must pursue their claims individually in arbitration, while the litigation is stayed.
What happened
Jean Pappas and four other travel nurses sued AMN Healthcare Services, alleging California Labor Code and related employment violations. They sought to bring the case as a class action, and defendants relied on arbitration clauses in the nurses’ employment agreements.
The Ninth Circuit had reversed an earlier order refusing to compel arbitration and sent the case back for an order requiring arbitration. Plaintiffs then sought to add three plaintiffs and raise arguments about the arbitration agreement that the Ninth Circuit had not addressed.
Judge Tiga denied the motion to amend, granted defendants’ motion to enforce the Ninth Circuit’s mandate, compelled each plaintiff to resolve individual claims through arbitration, dismissed the class and collective allegations, and stayed the entire litigation.
The detailed version
- Pappas v. AMN Healthcare Services · No. 4:24-cv-01426
- Jon Tigar
- Aug. 17, 2026
Background
Five travel nurses employed by AMN Healthcare Services filed a putative class action alleging violations of the California Labor Code and related employment claims. Defendants moved to require the plaintiffs to arbitrate their individual claims under arbitration clauses in their employment agreements.
The district court initially denied that motion, finding the arbitration agreement both procedurally and substantively unconscionable and declining to sever the arbitration provision. Defendants appealed. The Ninth Circuit reversed, holding that the district court had misinterpreted the arbitration clause and that the clause was not substantively unconscionable. The Ninth Circuit sent the case back for an order compelling arbitration.
Motions and Analysis
Plaintiffs sought leave to add three new plaintiffs who would assert arguments about the invalidity of the AMN arbitration agreement that the Ninth Circuit had not addressed. Defendants moved to enforce the Ninth Circuit’s mandate and requested an order compelling arbitration, dismissing the class and collective allegations, and staying further litigation. Each side opposed the other’s motion.
The court granted defendants’ motion and denied plaintiffs’ motion. Because the court was required to refer the plaintiffs’ claims to arbitration, the Federal Arbitration Act required the court to stay the action until the arbitration was completed under the agreement’s terms. The court held that it could not lift the stay to allow plaintiffs to add new plaintiffs or grant the proposed amendment before carrying out the Ninth Circuit’s directive. The court also stated that a plaintiff required to arbitrate individual claims may not pursue class claims as a representative.
Disposition
The court denied plaintiffs’ motion for leave to file an amended complaint. It granted defendants’ motion to enforce the Ninth Circuit’s mandate and granted defendants’ motion to compel arbitration. Each plaintiff was compelled to resolve the plaintiff’s claims through individual arbitration, and the class and collective allegations were dismissed. The court stayed the entirety of the litigation under Section 3 of the Federal Arbitration Act.
The Clerk was directed to administratively close the file. The court stated that the order was not a dismissal or disposition of the action against any party and that any party could initiate further proceedings in the same manner if further proceedings became necessary.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.