ADR CORNER
UPCOMING SECTION NETWORKING EVENTS
ADR CORNER
Arbitration Case Law Update( Continued)
DONNA GREENSPAN SOLOMON
Flowers Foods, Inc. v. Brock, No. 24-935, 2026 WL 1485669( U. S. May 28, 2026). In construing the scope of the Federal Arbitration Act ' s( FAA) exemption for class of workers engaged in interstate commerce, cases using the same language as the exemption, or formulations very close to it, offer probative evidence of what an ordinary person at the time of the FAA ' s enactment would have understood its terms to mean.
Jules v. Andre Balazs Properties, 146 S. Ct. 1209( 2026). A federal court with pre-existing jurisdiction over claims that it has stayed pending arbitration under the Federal Arbitration Act( FAA) can adjudicate a motion to confirm or vacate an arbitral award under the FAA even if that motion does not present, on its face, an independent basis for federal jurisdiction, as a court with the power to stay the action, under the FAA provision governing stays of proceedings where an issue therein is referable to arbitration, has the further power to confirm or vacate any ensuing arbitration award.
Tejon v. Zeus Networks, LLC, 174 F. 4th 1322( 11th Cir. 2026). Under Florida law, anyone who seeks to enforce an arbitration clause through a browsewrap agreement must prominently display the hyperlink that leads to the clause; consumers cannot be required to hover their mouse over otherwise plain-looking text or aimlessly click on words on a page in an effort to ferret out hyperlinks.
Donna is the current Chair of The Florida Supreme Court Committee on Standard Jury Instructions— Contract and Business Cases. Donna can be reached at( 561) 762-9932 or Donna @ SolomonAppeals. com or by visiting www. solomonappeals. com.
For additional ADR tips and resources, go to www. palmbeachbar. org / alternativedispute-resolution-committee.
UPCOMING SECTION NETWORKING EVENTS
NCS Happy Hour Thursday, August 13 th, 2026 5:30 P. M. – 7:30 P. M. Location TBA
YLS Happy Hour Thursday, september 17 th, 2026 5:30 P. M.- 7:30 P. M. Location TBA
Donna Greenspan Solomon was the first attorney certified by The Florida Bar as both Business Litigator and Appellate Specialist. Donna is a Member of the National Academy of Distinguished Neutrals and serves as Chair on AAA( Commercial Panel) and FINRA arbitrations. She is a Certified Circuit, Appellate, and Family Mediator and Florida Supreme Court Qualified Arbitrator.
PBCBA BAR BULLETIN 6