First Options of Chicago, Inc. v. Kaplan (1994)
- Docket
- 94-560
- Decided
- 1994-01-01
Summary
Question: Is the arbitrability of disputes subject to independent review by the courts? Should courts of appeals apply an "abuse of discretion" standard when reviewing district court upholding arbitration awards? Conclusion: Yes and no. In a unanimous opinion delivered by Justice Stephen G. Breyer, the Court held that the arbitrability of the Kaplan/First Options dispute was subject to independent review by the courts and that, rather than a special abuse of discretion standard, courts of appeals should apply ordinary standards when reviewing district court decisions upholding arbitration awards. "We conclude that, because the Kaplans did not clearly agree to submit the question of arbitrability to arbitration, the Court of Appeals was correct in finding that the arbitrability of the Kaplan/First Options dispute was subject to independent review by the courts," wrote Justice Breyer for the Court.