Rowe v. JPMorgan Chase Bank, N.A.
2:23-cv-01704-EAS-EPD
S.D. OhioMar 25, 2024Background
- Plaintiff Antar Rowe sued JP Morgan Chase Bank, N.A., asserting claims that were subject to an arbitration clause in his employment documents.
- In January 2024, the district court granted the defendant’s motion to compel arbitration, dismissed Rowe’s consolidated cases without prejudice, and entered judgment.
- Rowe immediately appealed and filed several post-judgment motions, including a motion to stay pending appeal and two motions to proceed in forma pauperis on appeal.
- Rowe argued he could not afford the appellate filing fee, noting his recent unemployment and current expenses.
- The court reviewed his financial affidavit and history, including substantial prior earnings and assets.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Stay pending appeal (arbitration order) | Stay necessary until appeal decided | No stay warranted; no likelihood of success | Denied; no likelihood of success or irreparable harm |
| Leave to proceed in forma pauperis | Cannot pay filing fee due to poverty | Rowe’s assets and history show ability to pay | Denied; financial affidavit did not show hardship |
| Request to amend in forma pauperis motion | Amending motion appropriate | — | Granted as to request to amend the motion |
| First in forma pauperis motion moot | — | — | Denied as moot |
Key Cases Cited
- Doctor’s Assocs. Inc. v. Casarotto, 517 U.S. 681 (1996) (arbitration agreement validity determined by general contract law principles)
- Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331 (1948) (in forma pauperis eligibility does not require absolute destitution)