Application Of Federal, Rather Than State Law, Resulted In Order Compelling Arbitration

Pennsylvania federal court has compelled a former employee to arbitrate claims against her former employer pursuant to an agreement requiring arbitration, rejecting her contention that, under Pennsylvania substantive law, she was relieved of the obligation to arbitrate because her complaint also named as a defendant a related company that was not subject to the arbitration requirement. In Hou v. Voya Insurance and Annuity Company, plaintiff argued that requiring her to pursue claims out arising out of the same events in both an arbitral and judicial forum was contrary to Pennsylvania precedent refusing to enforce arbitration requirements when a plaintiff has claims against multiple defendants, certain of which are not subject to arbitration.

Noting that plaintiff’s claims in the instant matter arose under federal law, the court held that “it is Federal law, not Pennsylvania law, that applies to this case.” Applying the ederal Arbitration Act, the court held that arbitration was required as to the claims against the former employer, while the claims against the related company would be litigated in the court.