Stolt-Nielsen v. Animalfeeds International Corp. (2009)
- Docket
- 08-1198
- Decided
- 2009-01-01
Summary
Question: Is imposing class arbitration on parties whose arbitration clauses are silent on that issue consistent with the Federal Arbitration Act? Conclusion: No. The Supreme Court reversed, holding that imposing class arbitration on parties who have not agreed to authorize class arbitration is inconsistent with the Federal Arbitration Act ("FAA"). With Justice Samuel A. Alito writing for the majority, the Court reasoned that in this case the arbitration panel exceeded its powers by imposing its own policy choice instead of identifying and applying a rule derived from the FAA or from maritime or New York law. The Court emphasized that the FAA adopts the basic principle that arbitration is a matter of consent, not coercion. Here, there was no consent. Justice Ruth Bader Ginsburg, joined by Justices John Paul Stevens and Stephen G. Breyer, dissented. She argued first that the petition for certiorari in this case was improvidently granted because the Court overturned the ruling of "experienced arbitrators." Moreover, even by reaching the merits of the case, she would have affirmed the Second Circuit and adhered to the "strict limitations" the FAA places on judicial review.