Manigault v. MacY's East, LLC
Carla Manigault sued Macy’s East, LLC and Terry Whittaker for alleged sexual harassment and retaliation under federal, New York State, and New York City human rights laws. Defendants sought to compel arbitration, citing Macy's "Solutions InSTORE" dispute resolution program which allowed employees to opt-out. The court denied the motion to compel arbitration, ruling that Manigault's mere silence and inaction did not constitute acceptance of the arbitration agreement under New York contract law. The court emphasized that a binding agreement requires clear manifestation of assent, which was absent despite Macy's efforts to inform employees about the opt-out procedure. The decision underscored the principle that an offeror cannot unilaterally create a contract based solely on an offeree's silence.