Washington v. American Arbitration Association

CourtDistrict Court, S.D. New York
DecidedJuly 9, 2025
Docket1:25-cv-00440
StatusUnknown

This text of Washington v. American Arbitration Association (Washington v. American Arbitration Association) 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
Washington v. American Arbitration Association, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK MARCUS WASHINGTON, Plaintiff, -against- AMERICAN ARBITRATION ASSOCIATION; PETER KEVIN CASTEL; ERIC KOMITEE; 25-CV-0440 (LLS) THE ESTATE OF ROBERT P. PATTERSON; EQUAL EMPLOYMENT OPPORTUNITY ORDER OF DISMISSAL COMMISSION; CHAROLETTE BURROWS;

KEITH SONDERLING; ANDREA LUCAS; KALPANA KOTAGAL; JOCELYN SAMUELS; KARLA GILBRIDE; YAW GYEBI; LISA MORELLI; WESLEY KATHARIA; DOLANDA YOUNG; RURY ARZU, Defendants. LOUIS L. STANTON, United States District Judge: Plaintiff, who is appearing pro se, brings this action against federal district court judges, the Equal Employment Opportunity Commission (EEOC) and its employees, and the American Arbitration Association (AAA).1 Plaintiff has been barred, however, from bringing suit against these individuals and entities without leave of court. Washington v. William Morris Endeavor Entertainment, LLC, No. 10-CV-09647 (PKC) (JCF) (S.D.N.Y. July 20, 2011) (ECF 59). The Court therefore dismisses this action, without prejudice to Plaintiff’s pursuing his claims, if any, against The Whitby Hotel, which is not named as a defendant in this action.

1 By order dated May 15, 2025, the Court granted Plaintiff’s request to proceed in forma pauperis, that is, without prepayment of fees. STANDARD OF REVIEW The Court must dismiss an in forma pauperis complaint, or any portion of the complaint, that is frivolous or malicious, fails to state a claim on which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B); see Livingston v. Adirondack Beverage Co., 141 F.3d 434, 437 (2d Cir. 1998). The Court must

also dismiss a complaint when the Court lacks subject matter jurisdiction of the claims raised. See Fed. R. Civ. P. 12(h)(3). While the law mandates dismissal on any of these grounds, the Court is obliged to construe pro se pleadings liberally, Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009), and interpret them to raise the “strongest [claims] that they suggest,” Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474 (2d Cir. 2006) (internal quotation marks and citations omitted) (emphasis in original). But the “special solicitude” in pro se cases, id. at 475 (citation omitted), has its limits – to state a claim, pro se pleadings still must comply with Rule 8 of the Federal Rules of Civil Procedure, which requires a complaint to make a short and plain statement showing that the pleader is entitled to relief.

BACKGROUND According to public records, Plaintiff is subject to a pre-filing injunction issued in Washington, No. 10-CV-9647. In that employment discrimination action, Judge Castel concluded that Plaintiff and his employer, William Morris Endeavor Entertainment LLC, had agreed to arbitrate issues of arbitrability (including whether the arbitration agreement was enforceable and the scope of the agreement), and Judge Castel therefore stayed the action pending an arbitration award. The arbitration award dismissed Plaintiff’s claims and directed Plaintiff to pay $43,7077.60 to the employer in costs and fees. By order dated September 5, 2014, Judge Castel granted the employer’s motion to confirm the award and, based on Plaintiff’s conduct in the course of litigation, enjoined Plaintiff from, among other things: filing or otherwise commencing any action in any federal district court arising out of or relating to this action or the arbitration proceeding before Arbitrators Gregory and Lewis against any person or entity including, but not limited to, defendants and their present or former employees, agents, or attorneys, the American Arbitration Association and its present or former employees or agents, arbitrators, or any judge, clerk, court reporter, employee or agent of any court of the United States of America without first obtaining a written order from this court authorizing him to do so. Washington, No. 10-CV-09647, ECF 59 (“the SDNY Filing Injunction Order”). Thereafter, in disregard of Judge Castel’s order, Plaintiff filed a new employment discrimination action, arising for his employment as a per diem substitute teacher with the New York City Department of Education, Washington v. United States of America, No. 1:23-CV- 05312 (EK) (PK) (E.D.N.Y.). Even though Plaintiff had been directed to seek permission before filing any suit against, among others, the American Arbitration Association, Arbitrator Timothy Lewis, and any federal judge or federal court employee, Plaintiff did not seek permission for his suit naming “the American Arbitration Association, Timothy Lewis, Michael P. Zweig, Christian Carbone,2 Judge Peter Kevin Castel, Judge Loretta A. Preska, the estate of Robert P. Patterson, the Southern District of New York, and the Second Circuit as defendants.” (ECF 4 at 6.) District Judge Komitee held that, in bringing suit against these defendants, “plaintiff is in violation of the SDNY Filing Injunction Order.” Id. Judge Komitee granted Plaintiff leave to file an amended complaint solely as to his employment discrimination claims against the NYC DOE, and terminated the other 45 defendants, in part based on Judge Castel’s SDNY Filing Injunction.

2 Attorneys Zweig and Carbone represented William Morris Endeavor Entertainment, LLC, in Washington, No. 10-CV-9647 (PKC). Judge Komitee cautioned Plaintiff that if he “continues to pursue frivolous claims, a broader filing injunction will become appropriate.” (Id. at 13.) Thereafter, on December 30, 2024, Plaintiff filed this action in the United States District Court for the Eastern District of New York, naming Judge Komitee, Judge Castel, the AAA, the

EEOC, the Estate of [former U.S. District Court Judge] Robert P. Patterson, and EEOC employees and officers.3 The complaint includes facts about (1) Plaintiff’s attempts to litigate his employment discrimination claims against William Morris Endeavor Entertainment, LLC before Judge Castel; (2) Plaintiff’s attempts to litigate his employment discrimination claims against the New York City DOE before Judge Komitee; and (3) termination of Plaintiff’s employment as an event manager at The Whitby Hotel, where he had worked for about three months, from July 2024 until October 27, 2024.4 Plaintiff states that he signed an arbitration agreement “as a condition of employment” at The Whitby Hotel, which provided that “all issues had to be resolved by the [AAA].” (ECF 1 at 2.) Plaintiff filed a discrimination charge with the EEOC,5 and then filed a demand for

arbitration with the AAA, in order to ensure that his Title VII claims would not be dismissed, even though he objects to arbitration “due to past fraud.” (Id. at 2.) Although Plaintiff provides

3 Plaintiff notes that Judge Patterson had presided over a separate suit against William Morris, Rowe Entertainment v. William Morris Agency, No. 98-CV-08272 (RPP) (JCF) (S.D.N.Y. Feb. 14, 2005). 4 Plaintiff alleges that on October 27, 2024, Plaintiff’s employment was terminated.

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Washington v. American Arbitration Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/washington-v-american-arbitration-association-nysd-2025.