Williams v. American Arbitration Association, Inc. et al

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
TERRENCE WILLIAMS,
Plaintiff,
v.
AMERICAN ARBITRATION
ASSOCIATION, INC., et al.,
Defendants
No. 25-cv-2505-ABA
MEMORANDUM OPINION
Plaintiff Terrence Williams sued Verizon Wireless in 2024 after it allegedly
refused to replace a cell phone that Mr. Williams contended was “not working.” ECF No.
18-1 at 3. He litigated that dispute in the Harford County Circuit Court and the Harford
County District Court, and arbitrated it before the American Arbitration Association,
Inc. (the “AAA”). He then sued the AAA and Marina Cortez, manager of ADR services at
the AAA (together the “AAA Defendants”), for abuse of process, tortious interference
with judicial proceedings, conspiracy, and violation of due process. He also sued Pavel
Ekmekchyan, Esq. and Yu Mohandesi, LLP (together the “Counsel Defendants”) for
abuse of process, tortious interference with judicial proceedings, and conspiracy. The
AAA Defendants and the Counsel Defendants have moved to dismiss based on, among
other things, arbitral immunity and litigation privilege. For the reasons provided below,
the Court will grant the motions and dismiss the complaint with prejudice.
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ALLEGATIONS AND PROCEDURAL HISTORY1
In May 2024, Plaintiff filed a lawsuit against the Counsel Defendants’ client,
Verizon Wireless, in Harford County District Court in connection with his dispute over
replacement cellular devices. ECF No. 18-1. The Verizon service agreement between
Plaintiff and Verizon limited Plaintiff’s remedies to arbitration or small claims court.
ECF No. 18-3 at 12.2 Therefore, Verizon moved to compel arbitration and, on August 27,
2024, the Harford County District Court granted the motion. ECF No. 1-1.
On August 30, 2024, Plaintiff filed an arbitration demand with the AAA, seeking
damages of $5,000. ECF No. 1-4 at 3; ECF No. 18-9. On September 24, 2024, Plaintiff
also appealed the order compelling arbitration. ECF No. 18-4.
On December 19, 2024, the Harford County Circuit Court held a hearing on
Plaintiff’s appeal and remanded the case to the Harford County District Court. ECF No.
1-2. The parties have not provided the transcript of the remand hearing, but it appears
that because Plaintiff’s damage claim met the requirements for small claims court
(under which the maximum for recoverable damages is $5,000, Md. Code, Cts. & Jud.
1 At the pleadings stage, the Court must “accept as true all of the factual allegations
contained in the complaint and draw all reasonable inferences in favor of the plaintiff.”
King v. Rubenstein, 825 F.3d 206, 212 (4th Cir. 2016). Additionally, the Counsel
Defendants have moved for judicial notice of various documents filed in the underlying
state cases. ECF No. 18. The Court will grant the motion and consider these exhibits
without converting the motions to dismiss into motions for summary judgment. The
court filings are matters of public record and Plaintiff has not challenged their
authenticity. Megaro v. McCollum, 66 F.4th 151, 157 (4th Cir. 2023). The documents are
also integral to Plaintiff’s complaint and incorporated therein, and he attaches several of
them to his complaint. Id.
2 Citations to the record refer to the ECF page numbers, which may differ from the
pagination used by the parties.
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Proc. § 4-405) and the arbitration provision of the service agreement allowed for the
case to proceed in small claims court, see ECF No. 18-3 at 12 (“EITHER YOU OR
VERIZON CAN CHOOSE TO BRING AN INDIVIDUAL ACTION IN SMALL CLAIMS
COURT INSTEAD OF PROCEEDING IN ARBITRATION”), the Circuit Court ordered
that the case “shall proceed before the District Court as a small claims action pursuant
to Md. Code Ann., Cts. & Jud. Proc. § 4-405 and that the Plaintiff/Appellant’s claim
shall not exceed the jurisdictional limits of a small claims action.” ECF No. 1-2.3
On January 10, 2025, the Harford County District Court lifted the stay pending
arbitration and ordered that the matter proceed to trial as a small claims case. ECF No.
1-3. But, on January 23, 2025, and despite the appellate court’s order cabining Plaintiff’s
damage claim, Plaintiff filed an amended complaint in the Harford County District
Court seeking compensatory damages of $8,540.00 as well as “consequential and
punitive damages,” which exceeded the small claims limit. ECF No. 18-7. Then, Plaintiff
voluntarily dismissed that case without prejudice on January 27, 2025. ECF No. 18-8.
On February 22, 2025, Plaintiff filed an amended arbitration claim with the AAA. ECF
No. 18-9. The AAA arbitration proceeding then continued into the summer of 2025. See,
e.g., ECF Nos. 1-4–1-5; ECF No. 18-9. Plaintiff alleges that during the renewed
arbitration process, he “objected in writing, but Defendants continued to press forward,
forcing Plaintiff to expend additional time and resources to defend against improper
arbitration.” ECF No. 1 ¶ 20.
3 The Circuit Court’s order does not specifically reverse the District Court’s order
compelling arbitration. Instead, the court merely ordered the case to proceed as a small
claims action. ECF No. 1-2. But given this Court’s holding below that the Defendants are
immune from Plaintiff’s claims, the exact posture on remand is not material.
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On July 31, 2025, Plaintiff filed this suit against Defendants, pro se. All of the
counts are directly related to conduct associated with the arbitration: In Count I, for
“Abuse of Process” against all Defendants, Plaintiff alleges that “Defendants used the
arbitration system for a purpose not legally justified, namely to override a valid court
ruling” remanding the case to proceed as a small claims action. ECF No. 1 ¶ 21. In Count
II, for “Tortious Interference with Judicial Proceedings” against all Defendants, Plaintiff
alleges that “Defendants knew that the matter had been remanded to District Court and
still took actions to undermine those proceedings.” Id. ¶ 23. In Count III, for “Civil
Conspiracy” against all Defendants, Plaintiff alleges that “Defendants acted in concert to
achieve an unlawful goal: resuming arbitration despite a court order ending it.” Id. ¶ 25.
In Count IV, for “Violation of Due Process” against Ms. Cortes, the AAA, and Mr.
Ekmekchyan, Plaintiff alleges that “Defendants deprived Plaintiff of liberty and property
interests by continuing legal proceedings without legal authority or court oversight.” Id.
¶ 27. In Count V, for “Declaratory and Injunctive Relief, “Plaintiff seeks a declaration
that AAA lacks jurisdiction to proceed with arbitration in this matter” and “a permanent
injunction prohibiting AAA, Cortes, Ekmekchyan, or Yu Mohandesi from pursuing,
administering, or enforcing arbitration in this case.” Id. ¶¶ 29–30.
The AAA Defendants filed a motion to dismiss on August 29, 2025, to which
Plaintiff filed a response. ECF Nos. 11 & 16. The Counsel Defendants filed motions to
dismiss and for judicial notice on September 2, 2025. ECF Nos. 17 & 18. Plaintiff did not
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file a response to either motion but did file a “Notice of Procedural Irregularity and
Request for Entry of Default” in connection with the Counsel Defendants. ECF No. 21.4
STANDARD OF REVIEW
A complaint must contain “a short and plain statement of the claim showing the
pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). When a defendant asserts that, even
assuming the truth of the alleged facts, the complaint fails “to state a claim upon which
relief can be granted,” the defendant may move to dismiss the complaint. Fed. R. Civ. P.
12(b)(6). To withstand a motion to dismiss, the complaint’s “[f]actual allegations must
be enough to raise a right to relief above the speculative level” and state a facially
plausible claim for relief. Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555, 570 (2007). “A
claim has facial plausibility when the plaintiff pleads factual content that allows the
court to draw the reasonable inference that the defendant is liable for the misconduct
alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). As noted above, when considering
such a motion, the Court “must accept as true all of the factual allegations contained in
4 In that filing, Plaintiff argues that the Counsel Defendants did not file a valid motion
and, thus, have not timely responded to the complaint. ECF No. 21. He argues that
Zachary Schlein, Esq. is listed as counsel on the docket for Mr. Ekmekchyan but there is
no counsel listed for Mr. Ekmekchyan’s law firm, Defendant Yu Mohandesi. Plaintiff
further argues that the motion to dismiss is not signed by Mr. Schlein, but by another
member of his firm. Although the motion is signed by another member of counsel’s firm,
the docket entry (ECF No. 17) establishes that Mr. Schlein filed the motion. The motion
also clearly pertains to both Counsel Defendants. ECF No. 17 at 1. It is clear to the Court
that the law firm engaged to defend the Counsel Defendants filed the brief on behalf of
both Defendants. Thus, the Court will deny Plaintiff’s request for an entry of default.
ECF No. 21.
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the complaint and draw all reasonable inferences in favor of the plaintiff.” King, 825
F.3d at 212.
Plaintiff is self-represented, so the Court construes his complaint liberally,
holding it to “less stringent standards than [those] drafted by lawyers.” Erickson v.
Pardus, 551 U.S. 89, 94 (2007) (quoting Estelle v. Gamble, 429 U.S. 97, 106 (1976)). But
“liberal construction of a pro se plaintiff’s pleading does not require the court to ignore
clear defects in pleading.” Chrisp v. Univ. of N.C.-Chapel Hill, 471 F. Supp. 3d 713, 716
(M.D.N.C. 2020).
DISCUSSION
Defendants raise several arguments in their motions, but all contend they are
immune to Plaintiff’s claims. The Court agrees with that assessment, which requires the
dismissal of the complaint with prejudice.
The AAA Defendants argue that arbitral immunity bars Plaintiff’s claims against
them. When “participating in the judicial process,” “judges, grand jurors, petit jurors,
advocates, and witnesses” have “absolute immunity . . . because of the special nature of
their responsibilities.” Butz v. Economou, 438 U.S. 478, 509–11 (1978). Given the
similarity between judicial and arbitral processes, courts have held that the immunity
extends to arbitrators such as Ms. Cortez as well as arbitration forums such as the AAA.
See Pfannenstiel v. Merrill Lynch, 477 F.3d 1155, 1159 (10th Cir. 2007) (“[C]ourts
uniformly hold that arbitration forums and sponsors, like courts of law, are immune
from liability for actions taken in connection with administering arbitration.”); Int’l
Med. Grp., Inc. v. Am. Arbitration Ass’n., Inc., 312 F.3d 833, 844 (7th Cir. 2002)
(finding the AAA immune from suit); New England Cleaning Servs., Inc. v. Am.
Arbitration Ass’n, 199 F.3d 542, 545 (1st Cir. 1999) (“In proper circumstances,
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organizations that sponsor arbitrations, as well as arbitrators themselves, enjoy this
immunity from civil liability.”); Hawkins v. Nat’l Ass’n of Sec. Dealers Inc., 149 F.3d
330, 332 (5th Cir. 1998) (finding that the arbitration forum “enjoy[ed] arbitral
immunity from civil liability for the acts of its arbitrators in the course of conducting
contractually agreed-upon arbitration proceedings.”), abrogated on other grounds by
Merrill Lynch, Pierce, Fenner & Smith v. Manning, ___ U.S. ___, 136 S. Ct. 1562
(2016); Olson v. Nat’l Ass’n of Sec. Dealers, 85 F.3d 381, 382 (8th Cir. 1996) (“[A]rbitral
immunity extends beyond arbitrators themselves to organizations that sponsor
arbitrations.”). Although the Fourth Circuit appears not to have addressed the issue, the
Court sees no reason the Fourth Circuit would depart from the conclusions of these
other circuits.
“Arbitral immunity protects all acts within the scope of the arbitral process.”
Olson, 85 F.3d at 383; New England Cleaning Servs., 199 F.3d at 545 (“A sponsoring
organization’s immunity extends to the administrative tasks it performs, insofar as these
are integrally related to the arbitration.”). Here, the acts that form the basis of Plaintiff’s
complaint are all clearly within the scope of the arbitral process, including that the AAA
allegedly “reopened the case, appointed an arbitrator,” and “began scheduling
proceedings” and that Ms. Cortes “issued formal notices, including arbitrator
appointment letters and compensation arrangements.” ECF No. 1 ¶¶ 17–18.
Plaintiff argues that the AAA Defendants’ acts were outside of the scope of the
arbitral process and therefore are not subject to immunity. He argues that the AAA
Defendants improperly restarted the arbitration process after the appellate court
remanded it to proceed as a small claims case, ignored that the arbitration was
previously closed, and acted contrary to the remand order. But it was Plaintiff who
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increased his demand so that his Harford County case could no longer be heard in small
claims court, then voluntarily dismissed that case days later, and then filed an amended
arbitration claim with the AAA. The Court concludes that the AAA Defendants’ actions
were within the scope of the arbitral process and they are therefore immune from
Plaintiff’s claims.
For the same reasons, the Counsel Defendants also have arbitral immunity as
Plaintiff essentially alleges that they wronged him by participating in the arbitration. See
Butz, 438 U.S. at 509–12 (discussing immunity for counsel). In addition, particularly
given the connection between the arbitration proceedings and the litigation in the
Harford County courts, the Counsel Defendants also argue that the litigation privilege
bars Plaintiff’s claims against them. As long as counsel’s allegedly tortious statements in
a case “have some rational relation to the matter at bar,” then they are subject to
“absolute privilege.” O’Brien & Gere Eng’rs, Inc. v. City of Salisbury, 447 Md. 394, 410
(2016) (quoting Norman v. Borison, 418 Md. 630, 650 (2011)). As with judicial
immunity, this privilege extends to quasi-judicial proceedings such as arbitration.
Norman v. Borison, 418 Md. 630, 652 (2011).
Here, Plaintiff alleges that the Counsel Defendants injured him based on their
filings, communications, and conduct during the arbitration proceedings, including that
Mr. “Ekmekchyan actively participated in” the reopened arbitration case, “pressed
forward” with the arbitration, and that the “Defendants acted in concert to achieve an
unlawful goal: resuming arbitration despite a court order ending it.” ECF No. 1 ¶¶ 19–
20, 25. Plaintiff seeks to hold the Counsel Defendants liable for participating in the
arbitration, but their actions during the arbitration are privileged. Therefore, the claims
against the Counsel Defendants must also be dismissed with prejudice.
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CONCLUSION
The Defendants are immune from Plaintiffs claims because Plaintiff merely
alleges that the Defendants participated in the arbitration and injured him through
actions that were within the scope of the arbitral process.
A separate order follows.
Date: January 12, 2026 	/s/
Adam B. Abelson
United States District Judge
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