AERSALE, INC. v. Aviation Personnel, LLC
2:24-cv-00980
D.N.M.Apr 14, 2025Background
- The case involves AerSale, Inc. seeking indemnity and contribution from various staffing partners regarding claims for unpaid overtime under the FLSA and New Mexico Minimum Wage Act, after the original action brought by an employee, Will Cruz.
- AerSale’s third-party claims against certain staffing partners were severed from the original class action and opened as a new case.
- Motions to dismiss and/or compel arbitration were filed by Hire Aviation Staffing Solutions (Hire), PSD Professional Services Development (PSD), and G-Force Aircraft Maintenance (G-Force).
- The parties agreed to arbitrate AerSale’s claims against Hire and PSD, while AerSale’s claims against G-Force are under separate consideration due to pending settlement discussions.
- The Court reserved judgment on subject matter jurisdiction, agreeing to stay the claims against Hire and PSD pending arbitration and taking G-Force’s motion under advisement for at least 30 days.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether court has federal question jurisdiction | AerSale: Jurisdiction present due to FLSA context | G-Force: No unique FLSA interpretation required; no federal question | Not decided; question reserved pending arbitration |
| Motion to dismiss or stay pending arbitration | AerSale: Pending arbitration appropriate | Hire & PSD: Support stay for arbitration; G-Force seeks dismissal/transfer | Claims against Hire/PSD stayed for arbitration |
| Court’s authority to grant stay under FAA | AerSale/Hire/PSD: Agreed to arbitration, want stay | Some case law suggests subject matter needed to stay under FAA | Court stays cases, reserves subject matter question |
| Motion to dismiss/transfer by G-Force | Not at issue (AerSale near settlement with G-Force) | G-Force: Requests dismissal or venue transfer | Motion under advisement for 30 days |
Key Cases Cited
- Mastrobuono v. Shearson Lehman Hutton, Inc., 514 U.S. 52 (1995) (federal policy strongly favors arbitration)
- Vaden v. Discover Bank, 556 U.S. 49 (2009) (FAA does not create independent federal jurisdiction; underlying dispute jurisdiction required)
- Arthur Andersen LLP v. Carlisle, 556 U.S. 624 (2009) (Section 3 allows federal courts to stay proceedings pending arbitration for cases already in federal court)
- Dietz v. Bouldin, 579 U.S. 40 (2016) (district courts have inherent authority to manage their dockets, including granting stays)
- Smith v. Spizzirri, 601 U.S. 472 (2024) (FAA contemplates district courts’ supervisory role over arbitration; jurisdiction required for key supervisory functions)
- Badgerow v. Walters, 596 U.S. 1 (2022) (courts must have subject matter jurisdiction over underlying dispute to supervise or enforce arbitration awards)