Friedman v. Sunrise Senior Living Management, Inc.

CourtDistrict Court, S.D. New York
DecidedMarch 31, 2025
Docket1:23-cv-08901
StatusUnknown

This text of Friedman v. Sunrise Senior Living Management, Inc. (Friedman v. Sunrise Senior Living Management, Inc.) 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
Friedman v. Sunrise Senior Living Management, Inc., (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

X : JEANNE V. FRIEDMAN, : 23 Civ. 8901 (GHW) (GS) : Plaintiff, : OPINION & ORDER : - against - : : SUNRISE SENIOR LIVING : MANAGEMENT, INC., : : Defendant. : :

X

GARY STEIN, United States Magistrate Judge: Plaintiff Jeanne V. Friedman (“Plaintiff” or “Friedman”) brings this action against Defendant Sunrise Senior Living Management, Inc. (“Defendant” or “Sunrise”) alleging, inter alia, that Sunrise unlawfully requested Friedman’s consumer credit history for purposes of employment in violation of the New York City Human Rights Law (“NYCHRL”), N.Y.C. Admin. Code § 8-502(a) et seq. Sunrise moves to stay this action and compel Friedman to arbitrate her claims under the Federal Arbitration Act (“FAA”), 9 U.S.C. § 1 et seq., pursuant to a Dispute Resolution Agreement entered into by the parties. (Dkt. No. 34). For the reasons set forth below, Sunrise’s motion is DENIED.1

1 On October 12, 2023, the Honorable Gregory H. Woods referred this action to the undersigned for general pretrial supervision, including non-dispositive motions, as well as all dispositive motions requiring a report and recommendation. (Dkt. No. 6). “District courts in this Circuit have regularly concluded that a motion to compel arbitration and stay litigation pending arbitration is non- dispositive and therefore within a Magistrate Judge’s purview to decide without issuing a report and recommendation pursuant to 28 U.S.C. § 636(b)(1)(B) and Fed. R. Civ. P. 72(b).” Martinez v. GAB.K, LLC, 741 F. Supp. 3d 26, 30 n.1 (S.D.N.Y. 2024) (citation omitted). Thus, the undersigned issues this decision as an Opinion & Order. BACKGROUND A. Factual Background2 In February 2023, Friedman, a registered nurse, applied and interviewed for employment at Sunrise, a national chain of senior living centers. (Compl. ¶¶ 1, 8). Friedman applied for a “wellness nurse” position at a Sunrise facility located in Manhattan. (Id. ¶ 8). Not long thereafter, on March 13, 2023, Sunrise sent an e-

mail to Friedman informing her that Sunrise was offering her the job. (Id. ¶ 9; Pl. Decl. Ex. 2 at 4). The e-mail included a link to an “Offer Letter and Background Packet” and provided the following instructions to Friedman: Please click on the link to review a copy of your offer letter. Should you choose to accept, check the electronic signature box, confirming your acceptance and complete the background forms proceeding. All forms must be completed to proceed with your acceptance. (Compl. ¶ 9; Pl. Decl. Ex. 2 at 9). Among other things, the Offer Letter (i) stated that Sunrise is “pleased to offer [Friedman] the position of Wellness Nurse RN”; (ii) provided a “projected start date” of March 27, 2023; (iii) set forth Friedman’s hourly rate and sign-on bonus; and (iv) informed Friedman that she “will be eligible to participate in the employee benefits program on the 1st of the month following [her] date of hire.” (Def. Decl. Ex. B). The Offer Letter further included the following paragraph: [I]t is Sunrise’s policy that all potential team members that have accepted a job offer must have drug screen,

2 The following facts are based on Plaintiff’s allegations in her operative complaint, filed on April 17, 2024 (Dkt. No. 31 (“Compl.”)), and the declarations and attached exhibits submitted in connection with Sunrise’s motion to compel arbitration from Linda Keech, a Sunrise employee with the title “Vice President of Total Rewards” (Dkt. No. 36-3 (“Def. Decl.”)), and Jonathan A. Bernstein, Friedman’s counsel (Dkt. No. 38 (“Pl. Decl.”)). background and reference checks completed. This offer is contingent upon the successful completion of your drug screen (which does not include marijuana), background investigation and reference checks. In addition, as a condition of employment, you are required to agree and sign the Sunrise Senior Living Dispute Resolution Agreement. (Id.). The Offer Letter requested that Friedman sign and return it, adding that the offer would expire in 72 hours. (Id.). The referenced “Sunrise Senior Living Dispute Resolution Agreement” (“Dispute Resolution Agreement” or “DRA”), which was also included in the linked package of documents sent to Friedman, proscribes a “three-step program” for the resolution of certain legal disputes between the parties, consisting of (i) direct communication; (ii) non-binding mediation; and (iii) if the dispute remains unresolved, binding arbitration administered by JAMS. (DRA at 1).3 In describing what disputes are subject to this program, the Dispute Resolution Agreement provides, in relevant part: We both agree to use the three-step program in this agreement to resolve any and all legal disputes that may come up between us during or after your employment that arise out of or relate in any way to your employment or its termination, except those disputes excluded below. This applies to legal disputes you may have against Sunrise Senior Living Management, Inc., its parents, subsidiaries and affiliates (collectively, “Sunrise”), and Sunrise’s officers, directors, shareholders, employees and agents. It also applies to legal disputes Sunrise may have against you. We both agree to waive our right to bring any such legal disputes before a judge or jury, and to waive our right to bring or participate in any such legal disputes on a class, collective, or representative action basis, and

3 Both parties submitted a copy of the Dispute Resolution Agreement in connection with Sunrise’s motion. (Pl. Decl. Ex. 1; Def. Decl. Ex. C). instead agree to have these legal disputes resolved exclusively on an individual basis under this agreement. (Id. (emphasis added)). The Dispute Resolution Agreement states that it “becomes effective on the date you sign below.” (Id. at 3). On the morning of March 14, 2023, Friedman signed the Offer Letter and the Dispute Resolution Agreement and electronically saved and submitted these documents to Sunrise. (Def. Decl. ¶¶ 13–14 & Ex. B at 2; DRA at 3; see also Compl.

¶ 10). Later that same morning, however, Friedman sent an e-mail to Sunrise stating that she was prompted “to sign a credit check query” and that “NYC employers violate the law (NYCHRL) should they request for employees or potential employees to sign such a document.” (Compl. ¶ 10; Pl. Decl. Ex. 2 at 3). Friedman concluded this e-mail by informing Sunrise that its electronic system would not allow her to continue without executing the authorization and asking Sunrise to advise her how to proceed. (Compl. ¶ 10; Pl. Decl. Ex. 2 at 4).

The parties engaged in an e-mail exchange discussing the credit check issue over the course of the next several weeks. (Compl. ¶¶ 11–14; Pl. Decl. Ex. 2). In the meantime, Friedman’s start date was postponed indefinitely. (Pl. Decl. Ex. 2 at 7). Ultimately, on April 6, 2023, Sunrise sent Friedman an email thanking her for her “interest in [the] position,” “wish[ing] [her] success in [her] career search,” and informing her if a position opens up that matches her qualifications, Sunrise will

contact her. (Compl. ¶ 15; Pl. Decl. Ex. 2 at 9). Construing this e-mail to constitute a withdrawal of Sunrise’s offer,4 Friedman initiated this action several months later, on October 10, 2023, alleging that Sunrise’s failure to hire her was an act of retaliation for Friedman’s refusal to authorize a credit check, and that such conduct

violates the NYCHRL. (Dkt. No. 1; Compl. ¶¶ 19–28).5 B.

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Friedman v. Sunrise Senior Living Management, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/friedman-v-sunrise-senior-living-management-inc-nysd-2025.