October 14, 2016 Second Circuit Bars Arbitration of Claim Subordination Dispute Appeals court easily rules against arbitration on a core issue involving priority. 2nd Circuit , December 22, 2015 Subordination Clause Held Ineligible for Arbitration Creditors bat 500 this fall when trying to compel arbitration in the Southern District of New York. 2nd Circuit , New York , New York Southern District ,