{"id":1943,"date":"2025-01-14T10:41:13","date_gmt":"2025-01-14T14:41:13","guid":{"rendered":"https:\/\/blogs.duanemorris.com\/classactiondefense\/?p=1943"},"modified":"2025-01-14T10:41:15","modified_gmt":"2025-01-14T14:41:15","slug":"dmcar-trend-4-plaintiffs-continue-to-chip-away-at-the-arbitration-defense","status":"publish","type":"post","link":"https:\/\/blogs.duanemorris.com\/classactiondefense\/2025\/01\/14\/dmcar-trend-4-plaintiffs-continue-to-chip-away-at-the-arbitration-defense\/","title":{"rendered":"DMCAR Trend #4 \u2013 Plaintiffs Continue To Chip Away At The Arbitration Defense"},"content":{"rendered":"\n<figure class=\"wp-block-gallery has-nested-images columns-default is-cropped wp-block-gallery-1 is-layout-flex wp-block-gallery-is-layout-flex\">\n<figure class=\"wp-block-image size-large\"><a href=\"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/01\/T4-DMCAR-2025-1.png\"><img loading=\"lazy\" decoding=\"async\" width=\"1024\" height=\"576\" data-id=\"1944\" src=\"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/01\/T4-DMCAR-2025-1-1024x576.png\" alt=\"\" class=\"wp-image-1944\" srcset=\"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/01\/T4-DMCAR-2025-1-1024x576.png 1024w, https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/01\/T4-DMCAR-2025-1-300x169.png 300w, https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/01\/T4-DMCAR-2025-1-768x432.png 768w, https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/01\/T4-DMCAR-2025-1-1536x864.png 1536w, https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/01\/T4-DMCAR-2025-1.png 1920w\" sizes=\"auto, (max-width: 767px) 89vw, (max-width: 1000px) 54vw, (max-width: 1071px) 543px, 580px\" \/><\/a><\/figure>\n<\/figure>\n\n\n\n<p><strong>By: Gerald L. Maatman, Jr.<\/strong><\/p>\n\n\n\n<p><strong><em>Duane Morris Takeaway:<\/em><\/strong><em> Despite another tumultuous year of rulings, the arbitration defense remained one of the most powerful weapons in the class action defense toolkit. A defendant\u2019s ability to enforce an arbitration agreement containing a class or collective action waiver continues to reign as one of the most impactful defenses in terms of shifting the pendulum of class action litigation. The U.S. Supreme Court cleared the last hurdle to widespread adoption of such agreements with its decision in Epic Systems Corp. v. Lewis, et al., 138 S. Ct. 1612 (2018). In response, more companies of all types and sizes updated their onboarding systems, terms of use, and other types of agreements to require that employees and consumers resolve any disputes in arbitration on an individual basis.<\/em><\/p>\n\n\n\n<p>Watch Review Editor Jerry Maatman explain this trend below:<\/p>\n\n\n\n<figure class=\"wp-block-embed is-type-video is-provider-youtube wp-block-embed-youtube wp-embed-aspect-16-9 wp-has-aspect-ratio\"><div class=\"wp-block-embed__wrapper\">\n<iframe loading=\"lazy\" title=\"Trend #4: Plaintiffs Continue To Chip Away At The Arbitration Defense\" width=\"525\" height=\"295\" src=\"https:\/\/www.youtube.com\/embed\/GTGsQbL0CnM?feature=oembed\" frameborder=\"0\" allow=\"accelerometer; autoplay; clipboard-write; encrypted-media; gyroscope; picture-in-picture; web-share\" referrerpolicy=\"strict-origin-when-cross-origin\" allowfullscreen><\/iframe>\n<\/div><\/figure>\n\n\n\n<p>To date, companies have enjoyed a high rate of success enforcing those agreements and using them to thwart class actions out of the gate. In 2024, although defendants continued to win most motions to compel arbitration filed, their margin of victory dwindled. Across substantive areas of class action litigation, courts issued rulings on approximately 167 motions to compel arbitration over the past year. Defendants prevailed in 91 of those rulings, a success rate of approximately 54%. These numbers are lower than the numbers we saw in 2023, where courts issued rulings on 187 motions to compel arbitration, and defendants prevailed on 123 motions, which translated into a success rate of 66%.<\/p>\n\n\n\n<figure class=\"wp-block-image size-full\"><a href=\"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/01\/Arbitration-Motions-2024.png\"><img loading=\"lazy\" decoding=\"async\" width=\"624\" height=\"351\" src=\"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/01\/Arbitration-Motions-2024.png\" alt=\"\" class=\"wp-image-1945\" srcset=\"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/01\/Arbitration-Motions-2024.png 624w, https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/01\/Arbitration-Motions-2024-300x169.png 300w\" sizes=\"auto, (max-width: 624px) 100vw, 624px\" \/><\/a><\/figure>\n\n\n\n<p>Given the potency of the arbitration defense, the plaintiffs\u2019 class action bar has continued to press potential exceptions to its coverage, including the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act (the Ending Forced Arbitration Act or EFAA) and the transportation worker exemption to the FAA. Over the past year, plaintiffs made significant strides on both fronts as courts issued a mixed bag of rulings. Plaintiffs continued to assert the EFAA to avoid arbitration of cases containing claims for alleged sexual harassment. And, despite the U.S. Supreme Court\u2019s guidance, many lower federal courts continued to apply the transportation worker exemption in a broad manner to workers who handled goods that moved in interstate commerce, irrespective of whether they played a direct role in transporting the goods across borders, such as last-mile delivery drivers, warehouse workers, and local distributors.<\/p>\n\n\n\n<ol start=\"1\" class=\"wp-block-list\">\n<li><a><strong>The Continued Impact Of The EFAA<\/strong><\/a><\/li>\n<\/ol>\n\n\n\n<p>The EFAA amended the FAA and provided plaintiffs the discretion to avoid pre-dispute arbitration provisions in cases where they allege conduct constituting \u201ca sexual harassment dispute or a sexual assault dispute\u201d or are the named representatives in \u201ca class or in a collective action alleging such conduct.\u201d In other words, the Act does not render arbitration agreements invalid but allows plaintiffs bringing sexual assault or sexual harassment claims to elect to avoid the agreements and to bring their cases in court instead of arbitration.<\/p>\n\n\n\n<p>In 2024, plaintiffs asserted the EFAA as a defense to approximately 47 motions to compel arbitration. Plaintiffs succeeded in enforcing the EFAA and keeping claims in court, in whole or in part, in approximately 27 of those rulings, or 57.4%. More than two years after the law\u2019s effective date, courts are continuing to define its parameters, and rules regarding the law\u2019s application are taking shape in multiple areas, the majority of which are coming out in favor of a broad application of the EFAA, making it easier for plaintiffs to avoid arbitration.<\/p>\n\n\n\n<p><strong><em>When Do Claims Arise?<\/em><\/strong><\/p>\n\n\n\n<p>Although by its terms the EFAA applies to any \u201cdispute or claim that arises or accrues\u201d on or after its enactment on March 3, 2022, courts have adopted varying interpretations of this language. Multiple decisions in 2024 showed that courts are receptive to arguments that the EFAA applies to conduct that occurred prior to the effective date of the Act so long as the plaintiffs file their charges or lawsuits after March 3, 2022.<\/p>\n\n\n\n<p>In<em> Famuyide, et al. v. Chipotle Mexican Grill Inc.<\/em>, 2024 U.S. App. LEXIS 19449 (8th Cir. Aug. 5, 2024), for example, the Eighth Circuit took a broad view as to when a dispute \u201carises\u201d for purposes of the Act. A former employee claimed that a co-worker raped her at work in 2021, months before the EFAA took effect. The Eighth Circuit, however, held that the dispute arose when the plaintiff filed her lawsuit in court in July 2022 and not when the sexual assault occurred in 2021 or even when her attorneys sent a demand letter to the defendant in February 2022 because the demand letter was not a \u201cconflict or controversy between the parties.\u201d <em>Id.<\/em> at *6.<\/p>\n\n\n\n<p>Similarly, in <em>Kader, et al. v. Southern California Medical Center Inc.<\/em>, 2024 Cal. App. LEXIS 50 (Cal. App. 2d Dist. Jan. 29, 2024), the Second Appellate District for the California Court of Appeal found that a dispute arose when the plaintiff filed charges with the Department of Fair Employment and Housing. An executive brought claims for sexual misconduct, as well as discrimination, retaliation, and defamation against a medical center alleging that it employed a doctor who sexually assaulted him. The defendant moved to compel arbitration based on an agreement that the plaintiff signed in 2019. The Court of Appeal concluded that the date a dispute arises \u201cdepends on the unique facts of each case\u201d but that \u201ca dispute does not arise merely from the fact of injury.\u201d Rather, \u201c[f]or a dispute to arise, a party must first assert a right, claim, or demand.\u201d <em>Id.<\/em> at *5.<\/p>\n\n\n\n<p><strong><em>What About Allegedly Continuing Violations?<\/em><\/strong><\/p>\n\n\n\n<p>In 2024, the Second Circuit weighed in on the impact of plaintiffs\u2019 alleging \u201ccontinuing violations,\u201d again in a way consistent with a broad interpretation of the EFAA. In <em>Olivieri, et al. v. Stifel, Nicolaus &amp; Company<\/em>, 112 F.4th 74 (2d Cir. 2024), the Second Circuit held that the EFAA shields claims from arbitration where the plaintiff alleges that the misconduct continued past the effective date of the law. Although the plaintiff alleged that she began experiencing a retaliatory hostile work environment before the effective date of the Act, and filed suit in January 2021, she claimed that the continuing course of conduct persisted after enactment of the EFAA, and, therefore, her claims were covered under the EFAA through the continuing violation doctrine. The Second Circuit agreed. The Second Circuit held that, while the plaintiff\u2019s claim did accrue before the EFAA went into effect given that she filed suit in January 2021, her claims continued to accrue again with each act she alleged added to the hostile work environment. The Second Circuit reasoned that, \u201c[i]f Congress wanted the EFAA to apply only to claims that \u2018first\u2019 accrue after its enactment, it could have said so.\u201d <em>Id.<\/em> at 89.<\/p>\n\n\n\n<p><strong><em>Does The EFAA Shield Tag-Along Claims?<\/em><\/strong><\/p>\n\n\n\n<p>The scope of the EFAA has been a hotly contested issue in terms of the breadth of its arbitration shield and whether it applies to all claims asserted by a plaintiff or only the sexual assault or sexual harassment claims. In October 2024, California\u2019s Second Appellate District held in <em>Yongtong Liu, et al. v. Miniso Depot CA Inc.<\/em>, 105 Cal. App. 5th 791 (Cal. App. 2d Dist. 2024), that the EFAA extends to a plaintiff\u2019s entire employment case, including a plaintiff\u2019s wage claims, shielding them from arbitration. A human resources employee brought suit against an employer alleging that the CEO made inappropriate comments regarding her appearance and sexual orientation. The employee also asserted wage &amp; hour claims for alleged misclassification, unpaid overtime, and minimum wage violations. The EFAA states, in relevant part, that \u201cno predispute arbitration agreement . . . shall be valid or enforceable with respect to a <em>case<\/em> which is filed under Federal, Tribal, or State law and relates to the . . . sexual harassment dispute.\u201d 9 U.S.C. \u00a7 402(a) (emphasis added). Focusing on the statute\u2019s use of the word \u201ccase,\u201d the appellate court ruled that the EFAA \u201cmakes the parties\u2019 arbitration agreement unenforceable as to [plaintiff\u2019s] entire case.&#8221; Such ruling runs counter to others, including the June 2023 decision in <em>Mera v. SA Hospitality Group LLC<\/em>, 675 F. Supp. 3d 442, 448 (S.D.N.Y. 2023), wherein a federal magistrate judge ruled that, although a restaurant chain could not force a plaintiff to arbitrate his sexual harassment claims, it could force him to arbitrate his wage &amp; hour overtime claims because they \u201cdo not relate in any way to the sexual harassment dispute.\u201d<\/p>\n\n\n\n<p>Companies should anticipate continued development of these and other novel issues as we continue further past the enactment date and plaintiffs continue to shift their interest toward the EFAA\u2019s arbitration shield.<\/p>\n\n\n\n<p><strong>#2. <a>The Impact Of The Transportation Worker Exemption<\/a><\/strong><\/p>\n\n\n<div class=\"wp-block-image\">\n<figure class=\"alignleft size-full\"><a href=\"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/01\/Picture1.jpg\"><img loading=\"lazy\" decoding=\"async\" width=\"317\" height=\"202\" src=\"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/01\/Picture1.jpg\" alt=\"\" class=\"wp-image-1946\" srcset=\"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/01\/Picture1.jpg 317w, https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/01\/Picture1-300x191.jpg 300w\" sizes=\"auto, (max-width: 317px) 100vw, 317px\" \/><\/a><\/figure>\n<\/div>\n\n\n<p>In one of the largest door-openers to the courthouse for the plaintiffs\u2019 class action bar, courts have issued a runaway train of rulings that position the transportation worker exemption to swallow up the FAA for workers who move or contribute to the movement of goods. Section 1 of the FAA exempts from arbitration \u201ccontracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce.\u201d The third category commonly is called the \u201ctransportation worker\u201d exemption. Although the U.S. Supreme Court has instructed lower courts to interpret the transportation worker exemption \u201cnarrowly,\u201d its parameters have carved a slippery slope for lower courts.<\/p>\n\n\n\n<p>In <em>Southwest Airlines Co. v. Saxon, et al.<\/em>, 142 S.Ct. 1783 (2022), the U.S. Supreme Court applied the transportation worker exemption to an airport ramp supervisor. Although it held that the exemption requires direct involvement in the transportation of goods across state or international borders, it had no problem finding the plaintiff part of such a class: \u201cWe have said that it is \u2018too plain to require discussion that the loading or unloading of an interstate shipment by the employees of a carrier is so closely related to interstate transportation as to be practically a part of it.\u2019 . . . We think it equally plain that airline employees who physically load and unload cargo on and off planes traveling in interstate commerce are, as a practical matter, part of the interstate transportation of goods.\u201d <em>Id.<\/em> at 1789.<\/p>\n\n\n\n<p>This ruling set off a barrage of decisions finding individuals who touch goods that move in interstate commerce, or the means of transport for such goods, subject to the exemption. As a result, in April 2024, the U.S. Supreme Court took up <em>Bissonnette, et al. v. LePage Bakeries Park Street, LLC<\/em>, 61 U.S. 246 (2024). As in <em>Saxon<\/em>, the U.S. Supreme Court emphasized that the test for application of the transportation worker exemption focuses on the work performed by the plaintiff and not the employer\u2019s industry. Addressing the employer\u2019s argument that its test would fold virtually all workers who load or unload goods, such as pet shop employees and grocery store clerks, into the exemption, the Supreme Court stated that the exemption has \u201cnever\u201d been interpreted to apply in \u201csuch limitless terms.\u201d <em>Id.<\/em> at 256. For the exemption to apply, the worker \u201cmust at least play a direct and necessary role in the free flow of goods across borders.\u201d <em>Id.<\/em><\/p>\n\n\n\n<p>The<em> Bissonnette<\/em> decision appears to have had a smaller impact on the lower courts, which issued opinions before and after <em>Bissonette<\/em> that broadly construe the transportation worker exemption.<\/p>\n\n\n\n<p>In May, for example, the California Court of Appeal in <em>Peters, et al. v. SDLA Courier Services<\/em>, 2024 Cal. App. Unpub. LEXIS 2954 (Cal. App. 2d Dist. May 14, 2024), found the plaintiff, a delivery driver who made only local deliveries of Amazon products, an exempt transportation worker. The plaintiff filed a class action alleging that the defendant violated various provisions of the California Labor Code, and the defendant moved to compel arbitration of the plaintiff\u2019s individual claims and to dismiss the class claims. The trial court denied the motion, finding the FAA inapplicable because the plaintiff was a \u201clast-leg delivery driver\u201d and \u201cengaged in interstate commerce.\u201d <em>Id.<\/em> at *2. The Court of Appeal affirmed, reasoning that, but for the plaintiff and those like her, the packages would not get delivered to customers.<\/p>\n\n\n\n<p>The Ninth Circuit also applied the transportation worker exemption broadly in three of its decisions this past year, both before and after <em>Bissonette<\/em>.<\/p>\n\n\n\n<p>On March 12, 2024, in perhaps the most aggressive application to date, the Ninth Circuit ruled in <em>Ortiz, et al. v. Randstad Inhouse Services, LLC<\/em>, 95 F.4th 1152 (9th Cir. 2024), that the plaintiff, a warehouse equipment operator responsible for moving packages to and from warehouse racks, qualified as a transportation worker. After plaintiff filed a class action for alleged wage &amp; hour violations, the defendant moved to compel arbitration, and the district court denied the motion. The Ninth Circuit affirmed. It found that the plaintiff \u201cactively engaged\u201d in transportation because he \u201censured that goods would reach their final destination by processing and storing them while they awaited further interstate transport.\u201d <em>Id.<\/em> at 1162. Further, it found that the plaintiff \u201cactively engaged\u201d with transportation because he handled goods \u201cas they went through the process of entering, temporarily occupying, and subsequently leaving the warehouse.\u201d <em>Id.<\/em><\/p>\n\n\n\n<p>On July 19, 2024, the Ninth Circuit affirmed the district court\u2019s ruling in <em>Lopez, et al. v. Aircraft Service International, Inc<\/em>., 107 F.4th 1096 (9th Cir. 2024). The plaintiff, a fueling technician at Los Angeles International Airport, initiated a wage and hour class action against his employer, who moved to compel arbitration. The district court denied the motion. It reasoned that, although the plaintiff did not handle goods in commerce, he was directly involved in the maintenance of the means by which the goods were transported. The Ninth Circuit affirmed. Although the plaintiff did not have any hands-on contact with goods or any direct participation in their movement, the Ninth Circuit reasoned that the plaintiff\u2019s work fueling airplanes was a \u201cvital component\u201d of the plane\u2019s ability to fly. <em>Id.<\/em> at 1101.<\/p>\n\n\n\n<p>On September 11, 2024, the Ninth Circuit issued another broad ruling in <em>Nair, et al. v. Medline Industries, LP<\/em>, 2024 WL 4144070 (9th Cir. Sept. 11, 2024). There, the plaintiff was a California warehouse operator who worked on a shipping dock stacking pallets and wrapping them in saran wrap. The plaintiff alleged that a driver told her that he made out-of-state deliveries and that a training video showed her employer shipping medical supplies throughout the country. The Ninth Circuit affirmed the district court\u2019s order denying a motion to compel arbitration, noting that the employer had done nothing to rebut the plaintiff\u2019s evidentiary showing that she packaged and loaded goods that traveled in interstate commerce. Justice Ryan Nelson\u2019s concurrence cautioned that the Ninth Circuit needed to ground its decisions in the statutory text of the transportation worker exemption rather than through \u201cjudicially created tests [that] risk taking on a life of their own.\u201d <em>Id.<\/em> at *2.<\/p>\n\n\n\n<p>The U.S. District Court for the District of Colorado followed this line of reasoning and issued a similar ruling in <em>Rietheimer, et al. v. United Parcel Service Inc<\/em>., No. 23-CV-477 (D. Colo. Nov. 13, 2024). The plaintiff, a last-mile delivery driver, filed a class action, and the defendant moved to dismiss the class claims and compel individual arbitration. The court ruled that the plaintiff and other last-mile delivery drivers like him were engaged in interstate commerce within the meaning of the transportation worker exemption. The court explained that, although the plaintiff did not directly transport goods across state lines, a significant portion of the packages he handled came from out of state, and his role was integral to the final step in the interstate delivery process. It reasoned that the packages the plaintiff delivered were part of an ongoing interstate transaction and thus concluded that he was directly involved in the free flow of goods across state borders. Given the enduring impact that the arbitration defense has in class action litigation, companies are apt to face additional hurdles from creative workarounds from the plaintiffs\u2019 class action bar as courts continue to push the boundaries of the transportation worker exemption.<\/p>\n\n\n\n<p><\/p>\n","protected":false},"excerpt":{"rendered":"<p>By: Gerald L. Maatman, Jr. Duane Morris Takeaway: Despite another tumultuous year of rulings, the arbitration defense remained one of the most powerful weapons in the class action defense toolkit. A defendant\u2019s ability to enforce an arbitration agreement containing a class or collective action waiver continues to reign as one of the most impactful defenses &hellip; <\/p>\n<p class=\"link-more\"><a href=\"https:\/\/blogs.duanemorris.com\/classactiondefense\/2025\/01\/14\/dmcar-trend-4-plaintiffs-continue-to-chip-away-at-the-arbitration-defense\/\" class=\"more-link\">Continue reading<span class=\"screen-reader-text\"> &#8220;DMCAR Trend #4 \u2013 Plaintiffs Continue To Chip Away At The Arbitration Defense&#8221;<\/span><\/a><\/p>\n","protected":false},"author":575,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[131],"tags":[],"ppma_author":[7],"class_list":["post-1943","post","type-post","status-publish","format-standard","hentry","category-duane-morris-class-action-review-2025"],"authors":[{"term_id":7,"user_id":575,"is_guest":0,"slug":"gmaatman","display_name":"Gerald L. Maatman, Jr.","avatar_url":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2022\/09\/maatmangerald-100x100.jpg","0":null,"1":"","2":"","3":"","4":"","5":"","6":"","7":"","8":""}],"_links":{"self":[{"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/posts\/1943","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/users\/575"}],"replies":[{"embeddable":true,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/comments?post=1943"}],"version-history":[{"count":0,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/posts\/1943\/revisions"}],"wp:attachment":[{"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/media?parent=1943"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/categories?post=1943"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/tags?post=1943"},{"taxonomy":"author","embeddable":true,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/ppma_author?post=1943"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}