Sophia Lewis v. American Express Company

CourtDistrict Court, D. Arizona
DecidedNovember 5, 2025
Docket2:24-cv-03370
StatusUnknown

This text of Sophia Lewis v. American Express Company (Sophia Lewis v. American Express Company) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sophia Lewis v. American Express Company, (D. Ariz. 2025).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Sophia Lewis, No. CV-24-03370-PHX-DWL

10 Plaintiff, ORDER

11 v.

12 American Express Company,

13 Defendant. 14 15 In December 2019, Plaintiff Sophia Lewis (“Lewis”) filed an administrative 16 complaint with the United States Department of Labor, Occupational Safety and Health 17 Administration (“OSHA”) in which she accused her then-employer, Defendant American 18 Express Company (“Amex”), of engaging in whistleblower discrimination. In August 19 2020, after being terminated by Amex, Lewis filed another administrative complaint with 20 OSHA, again accusing Amex of whistleblower retaliation. These complaints were 21 consolidated and the resulting administrative proceedings stretched on for several years. 22 In November 2024, while the administrative proceedings were still ongoing, Lewis filed 23 this action in federal court against Amex pursuant to the so-called “kick-out” provision of 24 the Sarbanes-Oxley Act of 2002 (“Sarbanes-Oxley” or “SOX”). 25 During the early stages of this case, Amex moved to dismiss Lewis’s claims as 26 untimely. (Doc. 9.) Amex argued that because SOX does not provide a limitations period 27 for filing a kick-out action, Lewis’s claims are governed by the four-year federal catch-all 28 statute of limitations in 28 U.S.C. § 1658(a). (Id.) Amex further argued that because 1 Lewis’s claims accrued no later than August 2020 (when she was terminated), she needed 2 to file this lawsuit by August 2024 in order to comply with § 1658(a)—and, thus, her 3 November 2024 filing came too late. (Id.) In response, Lewis identified three reasons why 4 Amex’s motion should be denied: “(1) Plaintiff’s [SOX] whistleblower claim is governed 5 by a statute of limitations already contained in SOX, meaning a 4-year general catch-all 6 provision does not apply; (2) if the Court did determine a general statute of limitations were 7 to apply, said statute was properly tolled during the pendency of her administrative 8 proceedings; and (3) equitable tolling principles further support the timeliness of Plaintiff’s 9 action under the circumstances of this case.” (Doc. 15 at 2.) 10 In a July 11, 2025 order, the Court denied Amex’s motion to dismiss. (Doc. 23.) 11 The Court only reached Lewis’s first argument, agreeing with her that “SOX creates a 12 limitations period for kick-out actions. Although this limitations period may be a bit 13 unusual—whereas most federal statutes require an action to be initiated in federal court 14 within a discrete number of months or years, SOX only creates a discrete time limit for the 15 initial filing of the administrative complaint and makes the time limit for filing an ensuing 16 kick-out action contingent on the timing of the resulting administrative process—it is still 17 a limitations period. As a result, § 1658(a) is, by its own terms, inapplicable—it only exists 18 to fill gaps ‘except as otherwise provided by law.’” (Id. at 12-13.) Given this 19 determination, the Court declined to reach Lewis’s alternative grounds for opposing 20 dismissal. (Id. at 16 n.9 [“The conclusion that § 1658(a) is inapplicable makes it 21 unnecessary to address the parties’ arguments regarding equitable tolling.”].) 22 Now pending before the Court is Amex’s motion to certify the denial of its motion 23 to dismiss for interlocutory appeal under 28 U.S.C. § 1292(b). (Doc. 26.) After the motion 24 became fully briefed (Docs. 30, 31), the Court issued a tentative ruling (Doc. 38) and held 25 oral argument (Doc. 39). 26 For the reasons that follow, Amex’s certification request is granted. However, 27 Amex’s related request for a stay of discovery pending appeal is denied. 28 … 1 DISCUSSION 2 I. Legal Standard 3 28 U.S.C. § 1292(b) provides in relevant part as follows: 4 When a district judge, in making in a civil action an order not otherwise appealable under this section, shall be of the opinion that such order involves 5 a controlling question of law as to which there is substantial ground for difference of opinion and that an immediate appeal from the order may 6 materially advance the ultimate termination of the litigation, he shall so state in writing in such order. 7 8 Id. As the Ninth Circuit has explained, “Section 1292(b) provides a mechanism by which 9 litigants can bring an immediate appeal of a non-final order upon the consent of both the 10 district court and the court of appeals.” In re Cement Antitrust Litig., 673 F.2d 1020, 11 1025-26 (9th Cir. 1981). To grant a § 1292(b) motion, a district court must find “that the 12 certification requirements of the statute have been met. These certification requirements 13 are (1) that there be a controlling question of law, (2) that there be substantial grounds for 14 difference of opinion, and (3) that an immediate appeal may materially advance the 15 ultimate termination of the litigation.” Id. at 1026. However, “[e]ven when all three 16 statutory criteria are satisfied, district court judges have unfettered discretion to deny 17 certification.” Brizzee v. Fred Meyer Stores, Inc., 2008 WL 426510, *3 (D. Or. 2008) 18 (citation omitted). See also Exec. Software N. Am., Inc. v. U.S. Dist. Court for Cent. Dist. 19 of Cal., 424 F.3d 1545, 1550 (9th Cir. 1994) (“[T]he district court must agree to certify 20 [an] order (a decision that itself is unreviewable) . . . .”); Heaton v. Soc. Fin., Inc., 2016 21 WL 232433, *2 (N.D. Cal. 2016) (“The decision to certify an order for interlocutory appeal 22 is committed to the sound discretion of the district court.”) (internal quotation marks 23 omitted). 24 Section 1292(b) is “to be used only in exceptional situations in which allowing an 25 interlocutory appeal would avoid protracted and expensive litigation.” In re Cement 26 Antitrust Litig., 673 F.2d at 1026. District courts should certify non-final orders under 27 § 1292(b) only in “rare circumstances,” and “[e]ven where the district court makes such a 28 certification, the court of appeals nevertheless has discretion to reject the interlocutory 1 appeal, and does so quite frequently.” James v. Price Stern Sloan, Inc., 283 F.3d 1064, 2 1067 n.6 (9th Cir. 2002). See also ICTSI Oregon, Inc. v. Int’l Longshore & Warehouse 3 Union, 22 F.4th 1125, 1131 (9th Cir. 2022) (“The appellant has the burden of persuading 4 the court of appeals that exceptional circumstances justify a departure from the basic policy 5 of postponing appellate review until after the entry of a final judgment. Although there is 6 little guiding that discretion in the text of § 1292(b) or our caselaw, it has been compared 7 to the discretion the Supreme Court enjoys when reviewing petitions for certiorari. For 8 example, this court may decline to exercise jurisdiction for reasons having little to do with 9 the appeal itself, such as docket congestion. Indeed, it need not offer any reason at all.”) 10 (cleaned up). 11 II. Analysis 12 Amex seeks to certify the following issue for interlocutory review: “[W]hether the 13 default four-year statute of limitations of 28 U.S.C. § 1658(a) applies to de novo actions 14 for whistleblower discrimination in violation of the Sarbanes-Oxley Act of 2002, 18 U.S.C. 15 § 1514A(a).” (Doc. 26 at 1.) 16 A.

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Sophia Lewis v. American Express Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sophia-lewis-v-american-express-company-azd-2025.