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Lamps Plus, Inc. v. Varela, No. 17-988 (Apr. 24, 2019)

Articles Discussing Case:

Ambiguity in Arb. Agreement Cannot Be Construed as Consent to Class Arbitration

Goldberg Segalla LLP • May 06, 2019
In Lamps Plus, Inc. v. Varela, the U.S. Supreme Court held that an ambiguous arbitration agreement cannot provide the necessary contractual basis for compelling class arbitration under the Federal Arbitration Act. This decision reverses the Ninth Circuit’s decision that permitted an employee’s data breach class arbitration to proceed.

SCOTUS: Ambiguity in Arbitration Agreement Cannot Be Construed as Consent to Class Arbitration

Goldberg Segalla LLP • May 02, 2019
In Lamps Plus, Inc. v. Varela, the U.S. Supreme Court held that an ambiguous arbitration agreement cannot provide the necessary contractual basis for compelling class arbitration under the Federal Arbitration Act. This decision reverses the Ninth Circuit’s decision that permitted an employee’s data breach class arbitration to proceed.

Supreme Court Strikes Down Classwide Employment Arbitration Claim

XpertHR • April 29, 2019
The Supreme Court has held that employees may not compel their employer to face classwide arbitration when an agreement is ambiguous as to whether the parties agreed to submit to class arbitration. The Court's 5-4 ruling in Lamps Plus, Inc. v. Varela, which divided along ideological lines, is the latest in a series of close decisions permitting companies to bar class actions both in court as well as in arbitration.

Supreme Court Says: Express Language Required to Arbitrate on a Class Basis

FordHarrison LLP • April 25, 2019
Executive Summary: Approximately one year ago, in Epic Systems Corp., the United States Supreme Court upheld the enforceability of mandatory arbitration agreements that prohibit employees from bringing employment claims on a class or collective basis – settling a longstanding circuit split over whether such provisions violate federal labor law. Just this week, the Supreme Court issued another important ruling in Lamps Plus, Inc., which clarifies that an employer cannot be compelled to arbitrate class and collective claims, unless the express language of its arbitration agreement authorizes such action. This decision marks the continued approval of arbitration agreements that require employees to individually arbitrate claims against their employers.

Supreme Court Confirms Class Arbitration May Not Proceed Unless Expressly Permitted by the Arbitration Agreement

Littler Mendelson, P.C. • April 25, 2019
On April 24, 2019, in a 5-4 opinion written by Chief Justice Roberts, the U.S. Supreme Court held that even if an arbitration agreement is ambiguous as to whether classwide arbitration is permitted, that is insufficient to find that the parties consented to class arbitration. Lamps Plus, Inc. v. Varela, No. 17–988 (2019). In doing so, the Court emphasized that there is a fundamental difference between class arbitration and the individualized form of arbitration envisioned by the Federal Arbitration Act (FAA). The Court’s decision firmly reinforces decades of precedent that arbitration is a matter of consent and aligns with its recent trend of pro-arbitration opinions.

eLABORate: Lamps Plus Decision Sheds Light on Class Arbitration Agreements

Phelps Dunbar LLP • April 25, 2019
On April 24, 2019, the United States Supreme Court in Lamps Plus v. Varela held that employees cannot bring class-wide claims in arbitration if the underlying arbitration agreement does not clearly and explicitly authorize class proceedings.

Supreme Court Holds Availability of Class Claims Must be Expressly Declared in Arbitration Agreements

Jackson Lewis P.C. • April 24, 2019
Class action arbitration is such a departure from ordinary, bilateral arbitration of individual disputes that courts may compel class action arbitration only where the parties expressly declare their intention to be bound by such actions in their arbitration agreement, the U.S. Supreme Court has ruled in a 5-4 decision. Lamps Plus, Inc. v. Varela, No. 17-988 (Apr. 24, 2019). “Courts may not infer from an ambiguous agreement that parties have consented to arbitrate on a classwide basis,” held the Court.