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BSF Secures Victory Before Ninth Circuit

Melissa Zonne
Melissa K. Zonne, Partner
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Maria Noah
Mariah J. Noah, Associate
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AUGUST 19, 2026

In the News

Partner Melissa Zonne and associate Mariah Noah secured a victory before the U.S. Court of Appeals for the Ninth Circuit, affirming that their client properly exercised her rights under the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act (EFAA) to pursue her sex harassment claims in court rather than arbitration.

The decision reinforces a key protection of the EFAA, confirming that employees who uncover evidence of sex-based harassment after initiating arbitration may continue pursuing their claims in their chosen forum. Melissa and Mariah received a shout-out in The American Lawyer’s Litigator of the Week and were quoted by Law360, Bloomberg Law, and Daily Journal.

THE AMERICAN LAWYER LITIGATION DAILY: Litigator of the Week Runners-Up and Shout-Outs

LAW360: 9th Circ. Says Initial Arbitration No Obstacle To EFAA

BLOOMBERG LAW: CFO’s Harassment Suit Can Stay in Court, Ninth Circuit Says

DAILY JOURNAL: Split 9th Circuit Lets Ex-CFO Leave Arbitration for Harassment Suit

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