Ninth Circuit Reverses District Court, Bars Non-Mutual Estoppel from Invalidating Aya Healthcare Arbitration Agreements
The Ninth Circuit has reversed a district court decision that used collateral estoppel to invalidate 255 arbitration agreements in a wage-and-hour dispute against Aya Healthcare Services, a travel nursing agency. In O'Dell v. Aya Healthcare Services, Inc. (No. 25-1528), the appeals court held that the lower court's selective application of prior arbitral rulings—taking only the unfavorable findings to block arbitration for opt-in employees—violated the Federal Arbitration Act. Writing for the panel, Judge Eric C. Tung emphasized that the FAA requires arbitration agreements to be enforced as written based on individualized consent, not through collateral estoppel or other non-contractual defenses.