Supreme Court Rules Trial Court Must Stay Litigation Pending Arbitration

May 29, 2024

 

What's New

The U.S. Supreme Court has ruled unanimously that federal district courts must stay, or temporarily suspend, legal proceedings rather than dismiss the lawsuit when they order the parties to participate in arbitration. The case, Smith v. Spizzirri, is an employee misclassification case involving a mandatory arbitration agreement. The Supreme Court’s ruling, published May 16, 2024, reinforces the federal policy favoring arbitration over litigation.

The Supreme Court reasoned that the plain language, structure, and purpose of the Federal Arbitration Act support this interpretation. Section 3 of the FAA states that a district court referring a case to arbitration “shall on application of one of the parties stay the trial of the action until such arbitration has been had.”

What It Means

This decision resolves a split among federal appeals courts. The Supreme Court here rejected the approach of the U.S. Courts of Appeal for the First, Fifth, and Eighth Circuits, which had permitted federal trial courts to dismiss lawsuits when claims are subject to arbitration. The Justices sided with the approach taken by the Second, Third, Sixth, Seventh, Tenth, and Eleventh Circuits, which had required trial courts to stay lawsuits while the arbitration process occurs.

This case concerns the federal arbitration statute, so its influence on state courts remains uncertain. However, many states have arbitration statutes modeled on the FAA, so this decision may be influential under state law as well.

What You Should Do

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