Stolt-Nielsen v. AnimalFeeds
From wikilawschool.net. Wiki Law School does not provide legal advice. For educational purposes only.
Stolt-Nielsen v. AnimalFeeds | |
Court | Supreme Court of the United States |
---|---|
Citation | 130 S.Ct. 1758, 559 U.S. 662 |
Date decided | April 27, 2010 |
Appealed from | 2nd Circuit |
Facts
- A parcel tanker is an ocean-sailing vessel with many compartments to hold liquid cargos.
- Each liquid compartment in the tanker may be chartered to a customer.
- AnimalFeeds International Corp. = "AnimalFeeds" = supplier of raw feeds to animal feed producers = customer of tanker companies
- Vegoilvoy = the charter party used by AnimalFeeds
- Vegoilvoy chart party included an arbitration clause stipulating application in New York of the Federal Arbitration Act
- The arbitration clause didn't specifically mention arbitration of class-action claims
- "Stolt-Nielsen" = a shipping company = AnimalFeeds shipping company = owner of tanker ships = plaintiff
- In 2003, the Justice Department found that Stolt-Nielsen participated in a price-fixing conspiracy
Procedural History
- AnimalFeeds brought a class-action lawsuit in federal court against Stolt-Nielsen.
- Next, AnimalFeeds demanded class arbitration.
- With the consent of the 2 opposing sides, a panel concluded that the arbitration clause in the contract didn't prohibit class arbitration
- AnimalFeeds won at the arbitration panel = the demand of AnimalFeeds for class arbitration is valid
- Afterwards, a federal district court vacated the decision of the arbitration panel = AnimalFeeds lost
- The 2nd Circuit reversed the federal district court in New York = AnimalFeeds won
Issues
Does the Federal Arbitration Act compel a party who never agreed to class arbitration to submit to class arbitration?
Holding
No. The Federal Arbitration Act doesn't require a party who never agreed to class arbitration to submit to class arbitration.
Judgment
Reversed
Reasons
Samuel Alito: Arbitration is a matter of consent, not coercion.
Resources
- Case text at Oyez
- Case text at Justia
- Case text at Legal Information Institute of Cornell Law School
- Video summary at Quimbee