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Russell v. Citigroup, Inc.

United States Court of Appeals for the Sixth Circuit
748 F.3d 677 (2014)


Facts

The first time that Keith Russell (plaintiff) worked for Citigroup, Inc. (defendant), he signed an agreement to arbitrate disputes. Russell worked in Citigroup’s call center from 2004 to 2009. In January 2012, Russell brought a class action against Citigroup claiming that the company did not pay employees for time spent logging in and out of their computers each day. Citigroup did not seek arbitration because the arbitration agreement covered only individual claims, not class actions. While the class action remained pending, Citigroup’s call center rehired Russell. Russell signed a second arbitration agreement that Citigroup had updated to include class actions. Russell did not consult with his attorneys before he signed the new arbitration agreement, and Citigroup’s outside counsel in the class action did not know Russell had been rehired. A month later, Citigroup found out and moved to compel arbitration even though the suit had begun discovery. The trial court denied the motion because the first arbitration agreement did not cover class actions. Citigroup filed an interlocutory appeal.

Rule of Law

Issue

Holding and Reasoning (Sutton, J.)

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