Arbitrator Misconduct-Federal Rules of Evidence-Discrimination

7^th Circuit Court of Appeals

Case Name: Sarah Hinkes v. Ravi Reddy

Case No.: 25-1268

Officials: Easterbrook, Rovner, and Scudder, Circuit Judges.

Focus: Arbitrator Misconduct-Federal Rules of Evidence-Discrimination

The Hinkes filed suit against her employer and two individual employees, alleging discrimination in violation of federal law. The case was stayed, pending arbitration pursuant to federal arbitration requirements. After the arbitrator entered an award in favor of the employer, Hinkes sought to vacate the award in the Northern District of Illinois. The district court confirmed the arbitration award.

The parties questioned whether subject-matter jurisdiction existed because complete diversity was lacking. Both Hinkes and one of the defendants, Ravi Reddy, were citizens of Illinois. Although Hinkes argued that Reddy’s citizenship should be disregarded because she was no longer pursuing relief against him, the court observed that he remained a party to the litigation. Hinkes subsequently moved to dismiss the appeal, but Sunera Technologies maintained that federal-question jurisdiction existed under 28 U.S.C. § 1331. Relying on recent decisions in Kinsella v. Baker Hughes Oilfield Operations, LLC and Jules v. Andre Balazs Properties, the Seventh Circuit concluded that because the underlying action arose under federal law, federal-question jurisdiction continued to support the district court’s authority to confirm the arbitration award.

The Seventh Circuit then addressed Hinkes’s substantive challenges to the arbitration award, which focused on alleged procedural errors and arbitrator misconduct under 9 U.S.C. § 10(a)(3). The court held that Hinkes failed to demonstrate misconduct warranting vacatur. Specifically, the arbitrator did not improperly exclude evidence and was not required to adhere to the Federal Rules of Evidence or federal discovery procedures.

Affirmed.

Decided 05/22/26

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