SAFONOVA v. HOME CARE SERVICES FOR INDEPENDENT LIVING, INC.

7299N. 150642/16.

165 A.D.3d 482 (2018)

85 N.Y.S.3d 58

2018 NY Slip Op 06805

Svetlana Safonova, Respondent, v. Home Care Services for Independent Living, Inc., Appellant.

Appellate Division of the Supreme Court of New York, First Department.

Decided October 11, 2018.


Plaintiff is bound by the arbitration provision in the collective bargaining agreement because the agreement was entered into while she was still employed, even though it was not ratified until after she resigned. "[A] union ratification vote is not always required for the provisions in a [collective bargaining agreement] to be considered validly formed" (Granite Rock Co. v Teamsters, 561 U.S. 287, 298-297 n 4 [2010]). Here, ratification...

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