Stolt-Nielsen v. AnimalFeeds

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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.


Ruth Bader Ginsburg dissented.

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