The Southern District of New York relied on the doctrine of arbitral immunity in dismissing a lawsuit brought by an aggrieved party against an arbitration administrator and the individual arbitrators who heard his claim.

In Funcia v. NYSE Group, No. 07 Civ. 1745, 2007 WL 4276897 (S.D.N.Y. Dec. 3, 2007), Funcia filed an unsuccessful arbitration claim alleging racial discrimination by ABN AMRO, his former employer.

Following arbitration, Funcia filed a lawsuit against ABN AMRO, again alleging racial discrimination and seeking an order vacating the arbitration award. The lawsuit was dismissed as time-barred.

Funcia later filed another lawsuit, this time naming the NYSE Group, which administered the arbitration, and the individual arbitrators as defendants. The NYSE Group and the arbitrators moved for dismissal pursuant to Rule 12(b)(6).

The Court dismissed the claims against the NYSE Group and the arbitrators based on the doctrine of arbitral immunity. In dismissing the claims on this basis, the Court explained that "[a]rbitrators and organizations that sponsor arbitration have absolute immunity from claims for damages arising from acts within the scope of the arbitral process."