Newly Released Decisions
In re: Application of financialright claims GmbH, No. 24-3171 (3d Cir. Oct. 22, 2025)
Court of appeals affirmed district court’s dismissal of appellant’s motion to compel arbitration under 9 USC § 4, which authorizes district courts that would, save for an arbitration agreement, have jurisdiction over “civil actions,” to issue an order compelling arbitration. Court of appeals held that appellee’s initiation of an ancillary discovery procedure under 28 USC § 1782 did not constitute a “civil action” for the purposes of 9 USC § 4.
Houghton v. Polychain Alchemy, LLC, No. 24-7243 (9th Cir. Oct. 21, 2025)
Court of appeals affirmed district court’s denial of defendant’s motion to compel arbitration, finding that defendant waived its right by engaging in over twenty months of litigation, despite knowing that plaintiff had accepted terms of use that included an arbitration provision. Even if defendant did not waive its right to compel arbitration, district court also properly held defendant did not have a right to arbitrate, as the agreement did not delegate the question of arbitrability to the arbitrator with a non-signatory and defendant could not invoke the arbitration agreement through equitable estoppel.
Ambrosia v. Blazesoft Ltd., No. 25-C-1723 (N.D. Ill. Oct. 21, 2025)
Court granted defendants’ motion to compel arbitration, finding that the arbitration agreement providing that questions of validity and interpretation be governed by the laws of Ontario, Canada, did not mean the agreement was governed by Ontario’s Arbitration Act. Instead, since Canada was a signatory to the New York Convention, the New York Convention’s provisions prevailed against those of other statutes. Court, therefore, dismissed arguments of unenforceability that were predicated on statutory violations, and the validity of the agreement was deemed to be an arbitrable issue.
In re FieldTurf Artificial Turf Marketing and Sales Practices Litigation, No. 17-MD-2779-MAS-TJB (D.N.J. Oct. 20, 2025)
Court granted plaintiff law firm’s motion to stay arbitration relating to a dispute arising from the allocation of attorney’s fees. Court held that the parties’ settlement agreement, which stated that any dispute arising from the settlement must be brought exclusively to the court, superseded an earlier agreement to arbitrate between two plaintiff law firms.
Young v. Solana Labs, Inc., No. 24-6032 (9th Cir. Oct. 20, 2025)
Court of Appeals affirmed district court’s denial of the defendants-appellants’ motion to compel arbitration holding that the contract at issue did not clearly and unmistakably delegate questions of arbitrability to the arbitrator in the case of non‑signatories like the defendants-appellants. Similarly, the defendants-appellants could not invoke the arbitration agreement through equitable estoppel, finding that plaintiff’s cause of action did not rely on or invoke the contract containing the arbitration agreement.
Xin Yang International Import & Export (Guangzhou) Co. Ltd. v. Azad International Inc., No. 2:23-CV-20418-MEF-AME (D.N.J. Oct. 20, 2025)
Court denied the respondent’ s motion to dismiss the petition to confirm arbitration award, holding that a motion to dismiss may only be directed at a pleading. Court reasoned that a petition to confirm an award pursuant to the New York Convention functions as a motion rather than a pleading. Court found there may be a factual disagreement as to whether the respondent was one of the parties to the underlying arbitration and therefore, ordered next steps including possible discovery to be taken under a magistrate judge.