McCarthy v. Citigroup Global Markets

2005 DNH 165
CourtDistrict Court, D. New Hampshire
DecidedDecember 15, 2005
DocketCV-04-477-JD
StatusPublished

This text of 2005 DNH 165 (McCarthy v. Citigroup Global Markets) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McCarthy v. Citigroup Global Markets, 2005 DNH 165 (D.N.H. 2005).

Opinion

McCarthy v. Citigroup Global Markets CV-04-477-JD 12/15/05 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

James W. McCarthy

v. Civil No. 04-cv-477-JD Opinion No. 2005 DNH 165 Citigroup Global Markets. Inc.

O R D E R

James W. McCarthy contends that his former employer,

Citigroup Global Markets, Inc. ("CGMI"), violated the New

Hampshire wage laws in the operation of the Capital Accumulation

Plan ("CAP"), which he participated in while employed at CGMI.

McCarthy and CGMI arbitrated his claims before a panel of the

National Association of Securities Dealers-Dispute Resolution,

Inc., as required by the parties' agreement. The panel denied

McCarthy's claims and requests for relief, and McCarthy brought

an action in this court, moving to vacate the panel's decision.

The court granted McCarthy's motion and remanded the case.

On remand, a new panel considered McCarthy's claims and requests

for relief and again denied them. McCarthy's motion to reopen

the case was granted, and he moves to vacate the panel's award

and to remand the case for a third arbitration proceeding. CGMI

opposes McCarthy's motion to vacate and moves to confirm the

award.1

1CGMI requested oral argument. Given the extensive record and the parties' memoranda, oral argument would not be of assistance to the court. LR 7.1(d). Background

James W. McCarthy was financial consultant at CGMI for

eighteen years, earning commissions and other compensation.

Beginning in 1993, McCarthy participated in the CAP, a stock

purchase plan offered by CGMI. The CAP permitted certain

employees, including McCarthy, to designate a portion of their

compensation to be used to buy restricted stock at a discounted

price. Participating employees, including McCarthy, elected in

writing to have income withheld from their payroll checks to be

used to buy shares of restricted stock. Participating employees

paid income taxes on the value of the stock upon vesting unless

they elected, as McCarthy did, to pay payroll taxes at the time

the money was deducted.

The "quid pro quo" for the discounted price of the stock was

that the shares did not vest when they were purchased, requiring

the participating employee to remain employed for two years after

the purchase before vesting would occur. If the employee did not

remain employed for that time, both the unvested shares and the

compensation that was used to buy them were forfeited to CGMI.

McCarthy left his employment with CGMI in May of 2003, before

some of the restricted shares of stock he had elected to purchase

under the CAP had vested. As a result, those shares, along with

the compensation that was used to purchase them, were forfeited

2 to CGMI. McCarthy disputed that result and sought arbitration,

as required by his agreement with CGMI. See James W. McCarthy v.

Citigroup Global Markets. Inc.. NASD-DR Case No. 2003-09195.

In the arbitration proceeding, McCarthy claimed that the CAP

vesting provisions unlawfully caused him to forfeit $257,346 in

compensation. He also claimed that CGMI violated the New

Hampshire wage laws by making unlawful deductions from his

compensation to purchase the shares, by failing to pay him

compensation in cash, and by withholding compensation after the

termination of his employment. Both McCarthy and CGMI argued

their cases under the New Hampshire wage laws, which they agree

apply in this case. The arbitration panel found in favor of CGMI

and against McCarthy. The panel's decision, however, was not

based on the New Hampshire wage laws, which the panel held were

irrelevant, but instead the panel resolved the case based on its

view of common practices in the securities industry.

McCarthy brought suit in this court seeking to have the

decision vacated and the case remanded. The court granted

McCarthy's motion, concluding that the arbitration panel's

decision was based on a manifest disregard for the governing law.

On remand, a second panel was convened to hear McCarthy's claims.

Again, the parties presented arguments based on the New Hampshire

wage laws. CGMI filed a "Motion for Judgment," asking the panel

to dismiss McCarthy's claims. McCarthy objected to the motion

3 and also moved to ■'■'poll" the arbitrators, arguing that CGMI was

asking the panel to disregard the law, despite this court's order

on remand, and asking the arbitrators to affirm that they would

follow the rulings stated in the remand order. The panel denied

both motions.

After a hearing, the panel issued its decision, titled

"Modified Award," denying McCarthy's claims and requests for

relief. The panel reviewed the procedural history of the case,

acknowledging this court's remand order. In the part of the

award titled "Panel's Report," the panel stated that it had

"fully considered all claims and defenses, including the

applicability of the New Hampshire Wage Laws, which were heavily

argued by both sides. After full consideration of the matter,

the Panel decided to deny all claims with prejudice." McCarthy

asks that the "modified award" be vacated and that the case be

remanded for a third arbitration proceeding.

Discussion

As the court explained in the previous order, "[j]udicial

review of an arbitrator's decision is extremely narrow and

deferential." Poland Spring Corp. v. United Food & Commercial

Int'l Union. 314 F.3d 29, 33 (1st Cir. 2002). The Federal

Arbitration Act provides certain limited grounds for vacating an

arbitration award. See 9 U.S.C. § 10. "[T]he statute ■'carefully

4 limits judicial intervention to instances where the arbitration

has been tainted in certain specific ways . . . [and] contains no

express ground upon which an award can be overturned because it

rests on garden-variety factual or legal [errors ] . ' " P .R . T e l .

Co. Inc. v. U.S. Phone Mfg. Corp, 427 F.3d 21, 25 (1st Cir. 2005)

(quoting Advest. Inc. v. McCarthy. 914 F.2d 6, 8 (1st Cir.

1990)); see also Poland Springs. 314 F.3d at 33 (court not

conducting appellate review "to hear claims of factual or legal

error by an arbitrator or to consider the merits of an award").

"An arbitrator's award must be enforced if it is in any way

plausible, even [if the court] think[s] [the panel] committed

serious error." Wonderland Greyhound Park. Inc. v. Autotote

Svs., Inc., 274 F.3d 34, 35 (1st Cir. 2001) (internal quotation

marks omitted).

The stringent standard of review leaves only rare

circumstances when an arbitration award will be vacated, "such as

when there was misconduct by the arbitrator, when the arbitrator

exceeded the scope of her authority, or when the award was made

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