Jordan v. Best Buy Co., Inc.
- Donovan Frank
- 0:24-cv-01066
- U.S. District Court · District of Minnesota
- 6
In Jordan v. Best Buy Co., Inc., Judge Frank denied plaintiffs Jewel Jordan and Michael Walsh's motion to reconsider the court's earlier order compelling arbitration, finding that Best Buy had not refused to arbitrate and that Jordan could still move forward by filing a formal arbitration demand.
Consumers who purchased recalled Insignia pressure cookers from Best Buy and whose claims may be subject to Best Buy's arbitration clause, particularly plaintiff Jewel Jordan whose claims were ordered into arbitration.
What happened
In Jordan v. Best Buy Co., Inc. (Civil No. 24-1066), Jewel Jordan and Michael Walsh filed a class action lawsuit against Best Buy seeking money damages related to recalled Insignia pressure cookers. In February 2025, the court ordered Jordan's claims into arbitration and stayed those claims pending that process. Jordan then sought to undo that ruling, arguing that Best Buy effectively refused to arbitrate by pointing her toward small claims court instead — which, she argued, meant the arbitration order should no longer stand.
Jordan asked the court to reconsider the arbitration order on two grounds. First, she argued that Best Buy committed misconduct (under a rule that allows courts to revisit decisions when an opposing party's fraud or misconduct prevented a fair resolution). Second, she argued that exceptional circumstances left her without a fair chance to pursue her claims. Her argument in both instances rested on the claim that Best Buy was refusing to arbitrate after having asked the court to send her claims there.
Judge Frank denied the motion to reconsider. The court found that Best Buy had not actually refused to arbitrate — rather, Jordan had never filed a formal arbitration demand with the American Arbitration Association, which is required to start the process under Best Buy's own terms and conditions. Because Jordan still had the ability to file that demand and move her case forward, the court found no misconduct and no exceptional circumstances. The court declined to revisit its earlier ruling, and the order compelling arbitration remains in place.
The detailed version
This opinion arises from a class action lawsuit by plaintiffs Jewel Jordan and Michael Walsh against Best Buy Co., Inc. over economic damages allegedly stemming from recalled Insignia brand pressure cookers. The case is before the United States District Court for the District of Minnesota, Civil No. 24-1066 (DWF/DTS), decided by United States District Judge Donovan W. Frank.
Background
In February 2025, the court granted Best Buy's motion to compel arbitration of Jordan's individual claims and struck Jordan's class allegations, while declining to strike Walsh's class allegations. The court stayed (paused) Jordan's claims pending arbitration. On May 1, 2025, plaintiffs' counsel sent a letter to Best Buy's counsel initiating an informal dispute resolution process as required by Best Buy's Terms and Conditions before arbitration can be commenced — covering Jordan and 205 other consumers. Best Buy responded on May 22, 2025, objecting that the letter did not comply with its Terms and suggesting that because claimed economic damages per person were under $120, the claims should be brought in small claims court rather than arbitration. Plaintiffs interpreted this as a refusal to arbitrate and sought permission to file a motion for reconsideration, which the court granted only as to the motion to compel arbitration.
Legal Standard
The court applied the standard for motions to reconsider, which are reserved for correcting manifest errors of law or fact or presenting newly discovered evidence, and require 'extraordinary circumstances.' Because the February 2025 order was not a final judgment, the court analyzed the motion under Federal Rule of Civil Procedure 60(b), which allows relief from an order for reasons including misconduct by an opposing party (Rule 60(b)(3)) or any other reason justifying relief (Rule 60(b)(6)).
Jordan's Arguments and the Court's Analysis
1. Rule 60(b)(3) — Misconduct: Jordan argued that Best Buy committed misconduct by asking the court to compel arbitration but then directing her to small claims court, thereby preventing resolution of her claims. To succeed under Rule 60(b)(3), Jordan needed to show by clear and convincing evidence that Best Buy's fraud, misrepresentation, or misconduct prevented her from fully and fairly presenting her case. The court rejected this argument because Best Buy maintained it was willing to arbitrate and pointed out that Jordan had never actually filed a formal arbitration demand with the American Arbitration Association (AAA), which is required under both the AAA Consumer Arbitration Rules and Best Buy's own Terms and Conditions to initiate arbitration. Without that demand being filed, the court found Best Buy was not refusing to arbitrate.
2. Rule 60(b)(6) — Catch-All Provision: Jordan also argued that exceptional circumstances left her without a full and fair opportunity to litigate. The court again rejected this, finding that because Jordan retains the ability to file an AAA arbitration demand herself, she has an available path forward and has not been denied an opportunity to pursue her claims.
The court also noted that it had already limited the scope of reconsideration to the motion to compel arbitration, and declined to reconsider the separate ruling striking Jordan's class allegations.
Disposition
The court denied plaintiffs' motion to reconsider (Doc. No. 79). The February 21, 2025 order compelling arbitration of Jordan's claims remains in effect. Jordan may proceed by filing a formal arbitration demand with the AAA.
Reviewer note from the AI+
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