News & Analysis as of

Motion to Compel Arbitration Agreements Equitable Estoppel

Ervin Cohen & Jessup LLP

Equitable Estoppel Can Be Invoked By a Non-Signatory Joint Employer to Compel Arbitration

Tell me if you have heard this one before: ten companies are sued by a former employee as “joint employers”, even though the employee technically worked for, and signed a binding arbitration agreement with, only one of them....more

Fuerst Ittleman David & Joseph

The Role of Delegation Clauses in Motions to Compel Arbitration When Your Family Member Signs an Arbitration Agreement

It happens every so often: someone signs an agreement to arbitrate legal claims, the agreement has a solid clause delegating arbitrability issues to an arbitrator, and then a member of that person’s family files a claim in...more

Seyfarth Shaw LLP

Arbitration Agreement Enforceable By Non-Signatory Alleged Joint-Employers

Seyfarth Shaw LLP on

Employees who sign an arbitration agreement with one company cannot avoid arbitration with related defendant-companies by arguing they were not parties to the agreement. The California Court of Appeal held that claims against...more

Carlton Fields

Tenth Circuit Finds Non-Signatory May Compel Arbitration Based on Equitable Estoppel

Carlton Fields on

Defendant SemGroup Corp. and intervenor-defendant Cypress Environmental Management-TIR appealed an Oklahoma district court order denying their motions to compel arbitration. The plaintiff, Robert Ferrell, was a Cypress...more

Morrison & Foerster LLP - Left Coast Appeals

This Week at the Ninth: Arbitration Two Ways

This week, the Ninth Circuit addresses the ability of non-parties to invoke arbitration agreements, and refreshes its law on the applicability of Eleventh Amendment sovereign immunity in the arbitration context. KIM NGO...more

Carlton Fields

Tenth Circuit Finds Equitable Estoppel Theories Allowed Non-Signatory to Rely on Arbitration Clause, Reverses Order Denying Motion...

Carlton Fields on

Plaintiffs Darrell Reeves and James King worked at Enterprise Products Partners through separate third-party staffing companies. Each plaintiff had a separate employment contract with his respective staffing company, which...more

Carlton Fields

Second Circuit Affirms Denial of Motions to Compel Arbitration in Suit Against Trump Corp. and Trump Family

Carlton Fields on

The Second Circuit recently affirmed the denial of motions to compel arbitration filed by, inter alia, the Trump Corp. and a nonparty from whom the plaintiffs sought discovery....more

Carlton Fields

West Virginia Federal Court Refuses to Force Non-Signatory to Participate in Arbitration

Carlton Fields on

Mountain Valley Pipeline LLC (MVP) contracted with U.S. Trinity Energy Services LLC for the construction and installation of the Mountain Valley Pipeline across property in Greenbrier County, West Virginia. Trinity...more

Fox Rothschild LLP

A Review: State-Law Principles Allowing A Nonsignatory To Enforce An Arbitration Provision Against A Signatory May Be Applied To...

Fox Rothschild LLP on

In cases involving contracts between U.S. companies, courts frequently allow a nonsignatory to a contract to enforce an arbitration provision in the contract against a signatory, when the signatory to the contract relies on...more

Morrison & Foerster LLP - Left Coast Appeals

This Week at the Ninth: Independent or Intertwined?

This week, the Ninth Circuit simultaneously issued two decisions addressing the circumstances in which equitable estoppel can require a plaintiff to arbitrate a claim absent an arbitration agreement with the defendant. In the...more

Jackson Lewis P.C.

Second Circuit: Investment Advisor Not Covered By Plaintiff’s Employment Arbitration Agreement

Jackson Lewis P.C. on

The U.S. Court of Appeals for the Second Circuit recently concluded that investment advisor Ruane Cunniff & Goldfarb must face a proposed class action under ERISA Section 502(a)(2) for breach of fiduciary duty relating to its...more

Carlton Fields

Eleventh Circuit Affirms Denial of Motion to Arbitrate Where Appellant Was Not a Party to Arbitration Agreement

Carlton Fields on

The Eleventh Circuit Court of Appeals recently affirmed the denial of a motion to arbitrate where the appellants were not parties to the agreements containing arbitration clauses. The court also concluded that equitable...more

Mintz - Arbitration, Mediation, ADR...

Enforcement of International Arbitration Agreements: SCOTUS Rules That the New York Convention (and FAA ch. 2) Are Not...

When all was said and done, the U.S. Supreme Court ruled unanimously on June 1, 2020 in effect that the New York Convention (i.e., the U.N. Convention on the Recognition and Enforcement of Foreign Arbitral Awards) and the...more

Shutts & Bowen LLP

Looking to Compel Arbitration? Recent Supreme Court Decision Suggests Additional Tools are Available

Shutts & Bowen LLP on

Sometimes compelling arbitration is simple. If the parties to a dispute signed an agreement to arbitrate, a signatory would normally be able to use that agreement as a basis to move to compel arbitration pursuant to the...more

Miller Canfield

U.S. Supreme Court Rules That Nonsignatory to International Arbitration Agreement May Compel Arbitration

Miller Canfield on

Can your business be compelled to defend an international arbitration brought by an entity with whom you never agreed to arbitrate? On June 1, 2020, a unanimous United States Supreme Court answered this question in the...more

Proskauer - Minding Your Business

Supreme Court Decides No Signature, No Problem

On June 1, 2020, the U.S. Supreme Court delivered a unanimous opinion regarding the relationship between domestic equitable estoppel and the enforcement of arbitration agreements. In GE Energy Power Conversion France SAS,...more

Carlton Fields

U.S. Supreme Court Holds Equitable Estoppel Can Allow Non-Signatories to Compel Arbitration Under the New York Convention

Carlton Fields on

The U.S. Supreme Court has held that equitable estoppel doctrines can be invoked by non-signatories seeking to compel arbitration under the Convention on the Recognition and Enforcement of Foreign Arbitral Awards....more

Saul Ewing LLP

U.S. Supreme Court: Non-Signatories to an International Contract Might Be Able to Compel Arbitration

Saul Ewing LLP on

In a unanimous decision, the U.S. Supreme Court recently ruled that a non-signatory to an agreement requiring arbitration for disputes might be able to compel arbitration under state law equitable estoppel arguments. The...more

Sheppard Mullin Richter & Hampton LLP

Supreme Court Opens the Door for Non-Signatories to Enforce Arbitration Agreements, Resolving Circuit Split

On June 1, 2020 the United States Supreme Court issued a unanimous decision in GE Energy Power Conversion Fr. SAS, Corp. v. Outokumpu Stainless USA, LLC, No. 18-1048, 2020 WL 2814297 (U.S. June 1, 2020), holding that the...more

A&O Shearman

U.S. Supreme Court Holds That Convention On The Recognition And Enforcement Of Foreign Arbitral Awards Does Not Prohibit...

A&O Shearman on

On June 1, 2020, the United States Supreme Court, in a unanimous decision by Justice Thomas, held that allowing non-signatories to an arbitration agreement to compel arbitration under the Convention on the Recognition and...more

Faegre Drinker Biddle & Reath LLP

SCOTUS Resolves Circuit Court Split on Whether Non-Parties Can Use Equitable Estoppel to Enforce an International Arbitration...

On June 1, the U.S. Supreme Court in GE Energy Power Conversion France SAS v. Outokumpu Stainless USA, LLC, 590 U.S. ___ (June 1, 2020) unanimously held that a non-party may enforce an international arbitration agreement...more

Jackson Walker

U.S. Supreme Court Decides Major International Arbitration Case

Jackson Walker on

For the first time in six years, the U.S. Supreme Court focused its attention upon the Convention on the Recognition and Enforcement of Foreign Arbitral Awards of 1958, commonly referred to as the “New York Convention,” to...more

Troutman Pepper Locke

Supreme Court Interprets New York Convention To Allow Arbitration Agreement Nonsignatories To Invoke International Arbitration

Troutman Pepper Locke on

The U.S. Supreme Court issued a unanimous decision on June 1 in GE Energy Power Conversion France SAS, Corp. v. Outokumpu Stainless USA, LLC, holding that, in some circumstances, even nonsignatories to an agreement may invoke...more

Troutman Pepper Locke

U.S. Supreme Court holds New York Convention does not conflict with domestic estoppel doctrines

Troutman Pepper Locke on

The international arbitration community has watched the case of GE Energy Power Conversion France SAS, Corp. v. Outokumpu Stainless USA, LLC with great interest. At issue is whether a nonsignatory to an arbitration agreement...more

Fox Rothschild LLP

U.S. Supreme Court Rules That Equitable Estoppel May Be Applied To International Contracts Governed By The New York Convention

Fox Rothschild LLP on

In cases involving contracts between U.S. companies, courts frequently allow a nonsignatory to a contract to enforce an arbitration provision in the contract against a signatory when the signatory to the contract relies on...more

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