Ninth Circuit Affirms District Court Order Granting Motion to Compel Arbitration of Discrimination Claims

In Jackson v. Applied Materials Corp., the Ninth Circuit Court of Appeals affirmed a district court order granting a motion to compel arbitration of the plaintiff’s discrimination and retaliation claims, finding the arbitration agreement entered into by the parties was valid and encompassed the disputes before the court.

The court did not address the underlying facts of the case in its memorandum opinion, other than to note the matter involved claims of discrimination and retaliation brought by Jackson against his former employer. In affirming the district court’s order granting the defendant’s motion to compel arbitration, the court noted it had jurisdiction to conduct a de novo review of the matter under 28 U.S.C. § 1291. Relying on Ninth Circuit authority confirming that the Federal Arbitration Act “requires that district courts refer cases to arbitration where a valid arbitration agreement covers the dispute at issue,” the court found that the district court properly granted the defendant’s motion to compel arbitration “because the parties entered into a valid arbitration agreement encompassing the dispute at issue.” Relying on additional Ninth Circuit precedent, the court also based its decision on a finding that Jackson did not establish any of the grounds for vacating, modifying, or correcting the underlying arbitration awards in favor of the defendant under 9 U.S.C. §§ 9–11. Finally, the court refused to consider arguments and allegations raised for the first time on appeal, and affirmed the district court’s order granting the defendant’s motion to compel arbitration.

Jackson v. Applied Materials Corp., No. 22-16673 (9th Cir. Oct. 18, 2023).