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Holsten v. Barclays Services LLC

4th Cir. No. 25-2173

Jan. 20, 2026

Amicus Curiae Brief for Metropolitan Washington Employment Lawyers Association, National Employment Lawyers Association, National Women’s Law Center, American Association for Justice, and Public Justice in Support of Appellee Aloma Holsten

 

Issues: (1) Whether the District Court erred by denying Barclays’ motion to compel arbitration on the basis that Holsten’s asserted Title VII hostile work environment claim constituted a “sexual harassment dispute” that rendered the valid and binding arbitration agreement between Barclays and Holsten unenforceable pursuant to the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA).

(2) Whether the District Court erred by holding that Holsten’s Title VII claim for hostile work environment discrimination on the basis of sex plausibly alleged sexual harassment under Rule 12(b)’s pleading standards, thereby invoking the EFAA.

 

Full Citation: Brief for Metropolitan Washington Employment Lawyers Association et al. as Amici Curiae Supporting Appellee, Holsten v. Barclays Services LLC, No. 25-2173 (4th Cir. Jan. 20, 2026).

 

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