Duke v. Luxottica U.S. Holdings Corp.
Split Score
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Case Summary
Disposition
Affirmed in Part
The Second Circuit held that plaintiff-appellee Janet Duke has Article III standing to pursue ERISA § 502(a)(2) plan-reformation relief on behalf of her pension plan, but lacks standing to seek monetary payments to the plan. It further ruled that the effective-vindication doctrine bars enforcement of an arbitration clause requiring Duke to bring her § 502(a)(2) claim in individual arbitration, affirmed the district court’s denial of a stay, and therefore affirmed in part and reversed in part the lower court’s order.
Circuit Split Identified
Legal Issue
Whether, in an interlocutory appeal under Federal Arbitration Act § 16(a)(1), the court of appeals may review the district court’s determination of Article III standing (subject-matter jurisdiction).
Circuit Positions
Appellate courts may review Article III standing/subject-matter jurisdiction in a § 16(a)(1) interlocutory appeal.
Appellate courts may not reach Article III standing in such appeals; review is limited to arbitrability.
Conflict Summary
Several circuits hold that an appellate court may examine a plaintiff’s Article III standing when reviewing a district court’s denial of a motion to compel arbitration or to stay litigation under FAA § 16(a)(1); the Third Circuit has held the opposite, limiting review to the arbitrability ruling itself.