Revis v. Schwartz
Darrelle Revis and his corporate entity Shavae, LLC, sued Neil Schwartz, Schwartz & Feinsod, LLC, and Jonathan Feinsod, alleging breach of fiduciary duty, breach of contract, and fraud. The claims arose from a standard representation agreement (SRA) and a separate oral marketing and endorsement agreement. Defendants moved to compel arbitration, arguing that the SRA, by incorporating NFLPA regulations and AAA rules, delegated arbitrability questions to an arbitrator. The Supreme Court granted the motion, compelling arbitration for all parties and staying the action. The Appellate Division affirmed, concluding that the contractual documents, including incorporated AAA rules, clearly and unmistakably evidenced an intent to delegate arbitrability to an arbitrator, extending even to nonsignatory defendants and Shavae, LLC, under the direct benefits theory of estoppel. A dissenting opinion argued that the SRA's arbitration clause was limited to disputes 'of this Agreement' (the SRA) and did not extend to the separate oral agreement, raising a factual question about Schwartz's role as an attorney for the marketing and endorsement deal.