Argent Trust Company v. Ramon DeJesus Cedeno, et al.

This case presents two questions: (1) whether a plan participant can only bring a lawsuit under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), as a representative of his or her entire ERISAgoverned benefit plan, and (2) whether a participant in an ERISA-governed benefit plan who asserts statutory ERISA claims can be compelled, pursuant to a binding arbitration provision, to submit his or her claims to individual arbitration. On multiple past occasions, parties have asked this Court to invalidate binding arbitration provisions as contrary to various federal laws or policies. Rights enshrined in those other statutes, parties claimed, could not be vindicated if parties were required to submit to individual arbitration. But in each instance this Court has made clear that the Federal Arbitration Act (“FAA”) requires that arbitration clauses be enforced, unless another federal statute evinces a clear intention by Congress to override the FAA’s commands. Two Circuits—the Ninth Circuit and Seventh Circuit (the latter of which ultimately invalidated an arbitration provision on other grounds)—have concluded that there is nothing in ERISA that would preclude individual arbitration of ERISA claims. But the Third, Sixth, and Tenth Circuits, as well as the Second Circuit in the instant matter, have reached the opposite conclusion in invalidating ERISA plan arbitration provisions. A split thus exists between Circuits that recognize the availability of individual arbitration for ERISA claims and Circuits that do not.