A federal court in New Jersey has compelled arbitration in a case involving a Spanish-speaking employee who alleged disability discrimination, whistleblower retaliation, and workers' compensation retaliation. despite the fact that she could not read or understand the English-language arbitration agreement she signed.
The Facts
Maria DeAngelis, a building cleaner with more than twenty years of experience, was hired by CSI International, Inc. in August 2019. During her onboarding, CSI employees verbally translated documents from English to Spanish. DeAngelis signed a job application that disclosed CSI's mandatory arbitration policy, and separately signed an Arbitration Agreement waiving her right to pursue employment-related claims in court.
After being terminated, DeAngelis filed suit in New Jersey state court alleging disability discrimination and hostile work environment under the New Jersey Law Against Discrimination (NJLAD), whistleblower retaliation under the Conscientious Employee Protection Act (CEPA), and retaliation in violation of the New Jersey Workers' Compensation Act. Defendants removed to federal court and moved to compel arbitration.
The Court's Ruling
United States District Judge Julien Xavier Neals granted the motion to compel arbitration, applying the summary judgment standard after limited discovery had been completed. The court's analysis addressed three challenges raised by DeAngelis.
Language is No Defense to Enforcement. The court reaffirmed the established rule that a party who signs a contract is conclusively presumed to understand and assent to its terms — even if that party cannot read the language in which the contract is written. Citing Morales v. Sun Constructors, Inc., 541 F.3d 218 (3d Cir. 2008), the court held that the inability to read, write, speak, or understand English is immaterial to the enforceability of an English-language agreement. Because CSI employees had translated the documents orally at onboarding and DeAngelis was on notice of the arbitration policy, assent was established.
No Fraud or Duress. DeAngelis argued she was fraudulently induced and signed under economic duress. The court rejected both arguments. On fraud, self-serving deposition testimony, without evidence of affirmative misrepresentation, was insufficient to create a genuine issue of material fact. On duress, the court held that conditioning employment on signing an arbitration agreement reflects ordinary economic pressure, not the wrongful or unlawful conduct required to void a contract.
Unconscionability — Partial Victory for the Employee. The court found the arbitration agreement procedurally unconscionable only to the ordinary extent inherent in any take-it-or-leave-it employment contract of adhesion, insufficient to void it. However, the court struck down the agreement's six-month limitations period as substantively unconscionable, finding it contrary to the public policies embodied in both NJLAD (a two-year limitations period) and CEPA (a one-year limitations period). Citing Rodriguez v. Raymours Furniture Co., 225 N.J. 343 (2016), the court severed the offending provision and enforced the remainder of the agreement.
Significance for Workers' Compensation Practitioners
This decision has practical implications for workers' compensation attorneys in New Jersey. Where an employer's arbitration agreement covers workers' compensation retaliation claims, as CSI's expressly did, employees may find themselves compelled to arbitrate rather than litigate, even if they did not fully understand the agreement they signed. The language barrier, standing alone, will not rescue a signatory from arbitration.
The court's severance of the shortened limitations period is a meaningful protection: courts will not allow arbitration agreements to compress the statutory windows that the Legislature built into NJLAD and CEPA. But the broader enforceability of such agreements remains firmly intact.
Employers should take note that oral translations during onboarding, combined with clear written disclosure in a job application, will be sufficient to establish assent. Employees and their counsel should scrutinize arbitration agreements for provisions, particularly shortened statutes of limitations, that may be severable on public policy grounds.
Related Resources
Primary Case
DeAngelis v. CSI International, Inc., Civil Action No. 23-3178 (JXN)(AME), 2026 WL 1209006 (D.N.J. May 4, 2026) → Westlaw
Federal Cases
Young v. Experian Information Solutions, Inc., 119 F.4th 314 (3d Cir. 2024) → Justia | FindLaw
Guidotti v. Legal Helpers Debt Resolution, L.L.C., 716 F.3d 764 (3d Cir. 2013) → CourtListener
Morales v. Sun Constructors, Inc., 541 F.3d 218 (3d Cir. 2008) → FindLaw
First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938 (1995) → CourtListener | Google Scholar
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) → CourtListener | Google Scholar
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) → CourtListener | Google Scholar
New Jersey Supreme Court Cases
Fazio v. Altice USA, 261 N.J. 90 (2025) → Google Scholar
Rodriguez v. Raymours Furniture Co., 225 N.J. 343 (2016) → CourtListener
Atalese v. U.S. Legal Services Group, L.P., 219 N.J. 430 (2014) → FindLaw | Google Scholar
Arafa v. Health Express Corp., 243 N.J. 147 (2020) → Google Scholar
Delta Funding Corp. v. Harris, 189 N.J. 28 (2006) → Google Scholar
Muhammad v. County Bank of Rehoboth Beach, 189 N.J. 1 (2006) → Google Scholar
Martindale v. Sandvik, Inc., 173 N.J. 76 (2002) → Google Scholar
Young v. Schering Corp., 141 N.J. 16 (1995) → Justia
Continental Bank of Pennsylvania v. Barclay Riding Academy, Inc., 93 N.J. 153 (1983) → Google Scholar
Rudbart v. North Jersey District Water Supply Commission, 127 N.J. 344 (1992) → Google Scholar
New Jersey Appellate Division Cases
Lahoud v. Anthony & Sylvan Corp., 481 N.J. Super. 29 (App. Div. 2025) → Google Scholar
Shammout v. MSX International RNS, LLC, No. 23-21563, 2025 WL 957419 (D.N.J. Mar. 31, 2025) → Not yet on free databases; accessible via Westlaw.
Hampton v. ADT, LLC, No. A-172-20, 2021 WL 1713295 (N.J. Super. Ct. App. Div. Apr. 30, 2021) → Google Scholar
Sitogum Holdings, Inc. v. Ropes, 352 N.J. Super. 555 (Ch. Div. 2002) → Google Scholar
Young v. Prudential Insurance Co. of America, 297 N.J. Super. 605 (App. Div. 1997) → Justia
Quigley v. KPMG Peat Marwick, LLP, 330 N.J. Super. 252 (App. Div. 2000) → Justia | FindLaw
Pierce v. Ortho Pharmaceutical Corp., 84 N.J. 58 (1980) (cited in procedural history) → Google Scholar
*Jon L. Gelman of Wayne, NJ, is the author of NJ Workers' Compensation Law (West-Thomson-Reuters) and co-author of the national treatise Modern Workers' Compensation Law (West-Thomson-Reuters).
Blog: Workers' Compensation
LinkedIn: JonGelman
LinkedIn Group: Injured Workers Law & Advocacy Group
Author: "Workers' Compensation Law" West-Thomson-Reuters
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© 2026 Jon L Gelman. All rights reserved.
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