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Court Raises the Bar on Appeals Following Voluntary Dismissal A plaintiff may not avoid arbitration and manufacture appellate jurisdiction simply by voluntarily dismissing his claims, the U.S. Ninth Circuit Court of Appeals recently decided. In doing so, the court stated that an earlier Ninth Circuit decision reaching the opposite conclusion had been effectively overruled by intervening U.S. Supreme Court precedent. The Ninth Circuit’s new ruling will make it easier for parties seeking to enforce arbitration agreements. Damien Langere filed a class action lawsuit against Verizon Wireless af...