Unlike vindication of federal statutory rights, vindication of rights arising under state statutory law is not a basis to refuse to enforce an arbitration agreement. Orman v. Citigroup, Inc., No. 11-07086 (S.D.N.Y. Sept. 12, 2012). Plaintiffs alleged that, if forced to arbitrate, they would not be able to vindicate their consumer rights arising under state law. Rejecting that argument, the court noted that, while arbitration terms that would prevent a plaintiff from vindicating federal statutory rights may not be enforced, the entire line of case law in which the vindication of statutory rights analysis was developed deals with federal, as opposed to state, statutory rights. The vindication of statutory rights doctrine derives from an inference that when Congress passed the Federal Arbitration Act, Congress did not intend to preempt rights it had created in other federal statutes. The court concluded there is no principled reason to apply the doctrine to bar arbitration of claims grounded in state laws that were not created by Congress.