Williams v. Katten, Muchin, & Zavis

Elaine Williams (plaintiff) was a partner of the law firm Katten, Muchin, & Zavis (firm) (defendant). Williams signed an arbitration agreement as part of her employment with the firm. The agreement incorporated the rules of the American Arbitration Association (association). An employment-discrimination dispute arose between Williams and the firm, and Williams attempted to bring her claims in federal district court. The firm successfully moved to compel arbitration, citing the arbitration agreement. In preparation for the arbitration hearing, Williams submitted discovery requests, including depositions for four specific individuals. At a prehearing-discovery conference, the arbitrator evaluated each discovery request and denied three of Williams’s deposition requests. The arbitrator ruled on each request and explained why deposing the individuals would be inappropriate, redundant, or unnecessary. At the end of arbitration, an award in Williams’s favor was issued, but the award did not provide Williams with the front pay or compensatory damages she had claimed. Williams filed a motion to vacate the arbitration award and reinstate her discrimination claims against the firm in federal court. Among other arguments, Williams claimed that the arbitrator denied her a fundamentally fair hearing by arbitrarily and capriciously denying her deposition requests. The court did not find merit in Williams’s other arguments and addressed her discovery claims.