Billboard Media, LLC v. Wray

CourtDistrict Court, S.D. New York
DecidedSeptember 25, 2024
Docket1:23-cv-07809
StatusUnknown

This text of Billboard Media, LLC v. Wray (Billboard Media, LLC v. Wray) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Billboard Media, LLC v. Wray, (S.D.N.Y. 2024).

Opinion

U DS OD CC U MSD EN NY T UNITED STATES DISTRICT COURT ELECTRONICALLY FILED SOUTHERN DISTRICT OF NEW YORK DOC #: _________________ BILLBOARD MEDIA, LLC, DATE FILED: 09 /25/2024

Petitioner, -against- 23 Civ. 7809 (AT) (SLC)

ORDER ADOPTING LAUREN WRAY, REPORT AND RECOMMENDATION Respondent. ANALISA TORRES, District Judge:

Petitioner, Billboard Media, LLC (“Billboard”), brings this petition to compel Respondent, Lauren Wray, to arbitrate certain employment-related claims (the “Petition”). Pet., ECF No. 1; Pet’r Mot., ECF No. 3; Pet’r Mem., ECF No. 4. The Court referred the Petition to the Honorable Sarah L. Cave for a report and recommendation. ECF No. 20. Before the Court is Judge Cave’s Report and Recommendation (the “R&R”), dated April 25, 2024, which recommends that the Petition be granted and Wray be compelled to arbitrate her claims against Billboard consistent with the arbitration agreement she signed on November 15, 2021 (the “Agreement”). See generally R&R, ECF No. 21; Agreement, ECF No. 5-2. On May 30, 2024, Wray filed timely objections to the R&R. Objs., ECF No. 24; see also Resp., ECF No. 25. For the reasons stated below, the Court OVERRULES Wray’s objections to the R&R, ADOPTS the R&R’s conclusions, and GRANTS the Petition. DISCUSSION1 I. Standard of Review A district court “may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” 28 U.S.C. § 636(b)(1)(C). The Court may

adopt those portions of the R&R to which no objection is made “as long as no clear error is apparent from the face of the record.” Oquendo v. Colvin, No. 12 Civ. 4527, 2014 WL 4160222, at *2 (S.D.N.Y. Aug. 19, 2014) (citation omitted). When a party makes specific objections, the court reviews de novo those portions of the R&R to which objection is made. 28 U.S.C. § 636(b)(1)(C); Fed. R. Civ. P. 72(b)(3). However, when a party “makes only conclusory or general objections, or simply reiterates the original arguments,” the court reviews the R&R “strictly for clear error.” Harris v. TD Ameritrade Inc., 338 F. Supp. 3d 170, 174 (S.D.N.Y. 2018) (citation omitted), aff’d, 837 F. App’x 841 (2d Cir. 2021) (summary order); see also Bailey v. U.S. Citizenship & Immigr. Serv., No. 13 Civ. 1064, 2014 WL 2855041, at *1 (S.D.N.Y. June 20, 2014) (“[O]bjections that are not clearly aimed at particular findings . . . do

not trigger de novo review.”). An R&R is clearly erroneous if the reviewing court is “left with the definite and firm conviction that a mistake has been committed.” Easley v. Cromartie, 532 U.S. 234, 242 (2001) (citation omitted); see also Travel Sentry, Inc. v. Tropp, 669 F. Supp. 2d 279, 283 (E.D.N.Y. 2009). II. Wray’s Objections Wray argues, first, that the Agreement’s delegation clause does not clearly and unmistakably delegate enforceability and unconscionability issues to arbitration. Objs. at 6–8. Wray raised the same argument before Judge Cave, which Judge Cave rejected. R&R at 14–15;

1 The Court presumes familiarity with the facts and procedural history of this action as detailed in the R&R and does not summarize them here. R&R at 2–7. see Opp. at 17–18, ECF No. 17; see also Objs. at 8 (“As noted above and in Respondent’s opposition brief . . .”). Because Wray’s objection “simply reiterates [her] original arguments,” the Court reviews the objection “strictly for clear error.” Harris, 338 F. Supp. 3d at 174. The Agreement plainly delegates to the arbitrator “the sole and exclusive authority to

resolve any dispute relating to the scope, interpretation, applicability, enforceability or formation of [the] Agreement, including but not limited to any assertion that all or any part of th[e] Agreement is void or voidable or is unconscionable.” Agreement at 2. As Judge Cave correctly explained, courts have routinely found similar or identical delegation clauses to “provide clear and unmistakable evidence of the parties’ intent to delegate.” R&R at 14 (citations omitted). Nevertheless, Wray argues—as she did in opposition to the Petition—that a separate clause of the Agreement providing that the “parties shall bear equally the arbitration administrative expenses and the arbitrator’s compensation . . . unless otherwise required pursuant to JAMS rules” renders the delegation clause ambiguous because JAMS’ Minimum Standards permit courts to adjudicate enforceability disputes when an agreement “conflicts” with the

Standards. Objs. at 6–8 (quoting Agreement at3). Wray’s argument fails even assuming the Standards are “rules,” see Resp. at 6 n.1, because Wray has not identified any “conflict” with the Standards. The parties’ Agreement unmistakably delegates enforceability and unconscionability to the arbitrator. Agreement at 2; R&R at 14–15. It incorporates JAMS rules with regard to cost- splitting. Agreement at 3. And, it further provides that that to the extent any JAMS “rules and/or procedures conflict with any express term of th[e] Agreement, . . . th[e] Agreement is controlling.” Id. at 2; R&R at 19. That the JAMS Minimum Standards might permit parties to bring an enforceability challenge in court in the event of a conflict with the Standards, and that the parties here refer to “JAMS rules” generally in a separate and unrelated provision of their Agreement, does not suggest that the Agreement itself conflicts with the Standards or otherwise call into question the Agreement’s plain delegation of enforceability to the arbitrator. Judge Cave’s conclusion to this effect is neither clearly erroneous nor contrary to law. See Travel Sentry, 669 F. Supp. 2d at 283.

Wray next contends that Judge Cave erred in construing Wray’s unconscionability arguments as going to the Agreement as a whole rather than the delegation clause specifically. Objs. at 8–9; R&R at 15–17. This argument lacks merit even under de novo review. Wray is correct that a court must address a party’s challenge to a delegation provision even if the argument “applies ‘equally’ to the whole contract.” Coinbase, Inc. v. Suski, 144 S. Ct. 1186, 1194 (2024) (quoting Rent-A-Center, W., Inc. v. Jackson, 561 U.S. 63, 71 (2010)). But the party’s argument must be “specific to the delegation provision” to be considered, and it will only be considered as applied to the delegation provision itself. Rent-A-Center, 561 U.S. at 74; see also id. at 72 (explaining that any challenge not made to the delegation provision “specifically” must be left “for the arbitrator”). For example, an argument that a general fee-sharing provision

“render[s] the entire Agreement invalid,” is not “an[] argument[] specific to the delegation provision” and will not be considered. Id. at 74 (emphasis omitted). But a court will consider whether an arbitration agreement’s fee-sharing provision “as applied to the delegation provision render[s] that provision unconscionable.” See id. Judge Cave correctly determined which of Wray’s arguments were directed specifically at the delegation clause and rejected them on the merits. R&R at 15–21. For example, Judge Cave addressed Wray’s argument that the delegation provision is unconscionable because it is “buried” within the Agreement, correctly finding the claim to be without merit. R&R at 18. The R&R further assessed whether the Agreement’s fee-splitting provision is unconscionable as applied to the delegation of enforceability, finding insufficient evidence that it is. See Rent-A-Center, 561 U.S.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Green Tree Financial Corp.-Alabama v. Randolph
531 U.S. 79 (Supreme Court, 2000)
TRAVEL SENTRY, INC. v. Tropp
669 F. Supp. 2d 279 (E.D. New York, 2009)
Harris v. TD Ameritrade Inc.
338 F. Supp. 3d 170 (S.D. Illinois, 2018)
Katz v. Cellco Partnership
794 F.3d 341 (Second Circuit, 2015)
Isaacs v. OCE Business Services Inc.
968 F. Supp. 2d 564 (S.D. New York, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Billboard Media, LLC v. Wray, Counsel Stack Legal Research, https://law.counselstack.com/opinion/billboard-media-llc-v-wray-nysd-2024.