On June 27, 2017, the First Department issued a decision in New York Marine and General Insurance Co. v. Jorgensen & Co., 2017 NY Slip Op. 05186, holding that fraud claims were subject to a broad arbitration clause, explaining:
The court correctly determined that the claims asserted against defendant Jorgensen, which plaintiff describes as essentially alleging fraud and intentionally dishonest conduct, are subject to arbitration pursuant to the broad arbitration clause in the parties’ Program Management Agreement. The complaint does not allege fraud in the inducement of the arbitration clause or fraud permeating the entire agreement.
(Internal quotations and citations omitted).