A&O Shearman | U.S. International Arbitration Digest | 2016-2025 Arbitration Decisions
U.S. International Arbitration Digest
This links to the home page

2016-2025 Arbitration Decisions

A collection of the most recent U.S. international arbitration decisions is available here. Decisions can be quickly retrieved by using the filter tools below.

Filter By:
and/or
  • In re: Application of financialright claims GmbH, No. 24-3171 (3d Cir. Oct. 22, 2025)
    10/22/2025

    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.

  • Spineway SA v. Strategos Group, LLC, No. 24-1584 (3d Cir. Mar. 18, 2025)
    03/18/2025

    Court of appeals affirmed district court’s order denying petition to confirm a foreign arbitration award because the arbitrator was not selected in accordance with the parties’ agreement.  Court of Appeals found that, despite a reference to the non-existent Geneva ICC in their agreement, the parties intended the ICC, not the Swiss Chambers’ Arbitration Institution (SCAI), to select the arbitrator and intended for the ICC rules to govern.  Since the arbitrator was selected under SCAI rules, in contravention of the parties’ agreement, the district court properly refused to confirm the award under the New York Convention.  

  • Jiangsu Beier Decoration Materials Co. Ltd. v. Angle World LLC, No. 23-2450 (3rd Cir. Aug. 8, 2024)
    08/08/2024

    Court of appeals affirmed district court’s denial of appellant’s renewed petition to confirm its foreign arbitration award.  Court of appeals found that the parties did not agree to arbitrate pursuant to Article IV of the New York Convention and that the district court properly applied Pennsylvania, as opposed to Chinese, law in determining whether the arbitration agreement was valid.  Further, court of appeals rejected appellant’s argument that district court should have granted comity to the Chinese court’s holding that the parties had a valid agreement to arbitrate.

  • CPR Management S.A. v. Devon Park Bioventures L.P., Nos. 20-2343 20-2344 (3d Cir. Nov. 22, 2021)
    11/22/2021

    Court affirmed the confirmation of an arbitration award by the district court.  Court found that the district court properly struck Defendant-appellant’s application for interpleader because it was procedurally not permitted under the FAA as a pleading, not a motion; that the district court properly confirmed the arbitration award because none of the four grounds for vacating an award applied; and that the court properly awarded prejudgment interest because Defendant-appellant’s argument that prejudgment interest should be eliminated failed to meet one of the three grounds for the modification of an arbitration award as the “promotion of justice” alone is insufficient.  Court also admonished Defendant-appellant for prematurely quitting the arbitration.

  • MarkDutchCo 1 B.V., et al v. Zeta Interactive Corp, No. 19-3845 (3rd Cir. Aug. 10, 2021)
    08/10/2021

    Court affirmed confirmation of an arbitral award in a dispute arising out of an interest purchase agreement between the parties.  Court found that defendant did not meet the “heavy burden” imposed by the FAA and the New York Convention because the parties bargained for an IPA that committed to resolving all disputes, procedural and substantive, before an arbitrator and reaffirmed that commitment when engaging in arbitration.

  • MZM Construction Company, Inc. v. New Jersey Building Laborers Statewide Benefit Funds, No. 18-CV-03791 (3d Cir. Sept. 14, 2020)
    09/14/2020

    Court of appeal affirmed district court order enjoining arbitration of employee benefits claims pending resolution of factual issues bearing upon whether fraud in the execution vitiated the formation or existence of the contract containing the arbitration provision.  Court of appeal held that pursuant to 9 USC § 4, the validity of the arbitration agreement concerned questions about the “making of the agreement to arbitrate” and was therefore a matter for the courts to decide in the absence of the parties having clearly and unmistakably referred those issues to arbitration in a written contract whose formation was not in issue.

  • Teamsters Local 177 v. United Parcel Service, No. 19-3510 (3d Cir. July 16, 2020)
    07/16/2020

    Court of appeals reversed district court’s order denying petitioner’s motion to confirm an arbitration award.  Court of appeals found there was sufficient Art. III “case or controversy” to confer subject-matter jurisdiction on district court to confirm the arbitration award, since under the FAA a party’s injury was only fully remedied by the entry of a confirmation order.

  • Williams; Stermel v. Medley Opportunity Fund II, LP, No. 19-2058 (3d Cir. July 14, 2020)
    07/14/2020

    Court of appeals affirmed district court’s order denying defendants’ motion to compel arbitration.  Court of appeals found that because plaintiffs were allowed to raise disputes in arbitration only under tribal law, and such limitations constituted a prospective waiver of their statutory rights, the arbitration agreement violated public policy and was thus unenforceable.

  • Bacon v. Avis Budget Group, Inc., No. 18-3780 (3d. Cir. May 18, 2020) 
    05/18/2020

    Court of appeals affirmed district court’s order denying defendants’ motion to compel plaintiffs to arbitrate their claims.  Pursuant to the FAA, court of appeals determined it had appellate jurisdiction over the denial of motions to compel arbitration regardless of whether they were final orders.  Court of appeals found that the U.S. plaintiffs did not assent to the arbitration provision for rental jackets where they were not adequately incorporated into the U.S. Agreements and that there were questions of fact concerning whether the Costa Rican plaintiff had reasonable notice of the arbitration agreement.

  • Richardson v. Coverall North America, Inc., No. 18-3393 (3d Cir. Apr. 28, 2020)
    04/28/2020

    Court of appeal reversed, vacated, and remanded a district court’s denial of a motion to compel arbitration.  Third Circuit found that the incorporation of the AAA rules clearly and unmistakably delegated the question of arbitrability to the arbitrators, finding this to be true even for “unsophisticated” parties. 

  • Marbaker v. Statoil USA Onshore Properties, Inc., No. 3:17-CV-01528 (3d Cir. Feb. 13, 2020)
    02/13/2020

    Court of appeals affirmed district court’s denial of motion to compel class arbitration, finding that bilateral arbitration clause in lease agreement between defendant and plaintiffs did not provide consent necessary for court to compel class arbitration to resolve disputes across multiple similar leases as a class.

  • PNY Technologies, Inc. v. Netac Technology Co., Ltd., No. 2-13-CV-06799 (3d Cir. Feb. 10, 2020)
    02/10/2020

    Court of appeals affirmed district court’s decision to confirm arbitral award. Court rejected appellant’s contentions that arbitrator’s damages figure was completely irrational and that arbitration manifestly disregarded the law, finding that appellant had failed to meet the high standard for court intervention.

  • Pennsylvania National Mutual Casualty Insurance Company v. New England Reinsurance Corporation, No. 19-1805 (3d Cir. Dec. 6, 2019)
    12/06/2019

    Court of appeals affirmed district court’s order compelling arbitration of the consolidated disputes in question before a new panel of arbitrators. 

  • Valentin v. ADECCO, No. 18-3489 (3d Cir. Sept. 18, 2019)
    09/18/2019

    Court of appeals affirmed district court’s granting of a motion to compel arbitration of employment disputes.  Court found that there was a valid agreement and that the dispute related to claims of employee discrimination that fell within the scope of the agreement.

  • Orn v. Alltran Financial, L.P., No. 18-3802 (3d Cir. July 12, 2019)
    07/12/2019

    Court of appeals affirmed district court’s order denying defendants’ motion to compel arbitration.  Court found there were no factual basis for defendant to invoke the theories of agent or third-party beneficiary to enforce the arbitration agreement as a non-signatory.

  • Sabre GLBL, Inc. v. Shan, No. 18-2079 (3d Cir. July 3, 2019) 
    07/03/2019

    Court of appeals affirmed the district court’s confirmation of the award of head start damages and reversed the judgment vacating the award of attorney’s fees, concluding there was no basis to disturb the arbitrator’s award.  Pursuant to the FAA, court held the arbitrator did not exceed his powers, did not deprive the parties of a fair hearing, and did not exhibit evident partiality.  Court declined to decide whether manifest disregard of the law remains a valid basis for vacatur, finding the parties had not briefed the issue and regardless, appellee had not shown relief would be warranted.
     

  • Edmondson v. Lilliston Ford Inc., No. 18-2203 (3d Cir. May 15, 2019)
    05/15/2019

    Court of appeals affirmed district court order denying appellant’s motion to vacate the arbitration award.  Court noted that appellant’s arguments that the arbitration agreement was void ab initio were previously rejected by both the district court and the court of appeals, and that a motion for relief from judgment may not be used to reargue issues that were previously resolved.  Court further found that appellant’s allegations of judicial bias were merely disagreements with the district judge’s rulings.

  • Monfared v. St. Luke’s University Health Network, No. 18-2850 (3d Cir. May 10, 2019)
    05/10/2019

    Court of appeals affirmed lower court decision to confirm an arbitration award. In determining whether the claims were subject to arbitration, court concluded that the phrase “if a dispute or claim should arise” was best understood as functionally equivalent to more standard language that would sweep in any claim relating to the plaintiff’s employment.

  • Thrivest Specialty Funding LLC v. White, No. 18-1639 (3d Cir. Apr. 26, 2019)
    04/26/2019

    Court of appeals vacated district court’s order enjoining plaintiffs from pursuing arbitration and remanded for further proceedings.  Court held that decisions on enforceability of funding agreements should be litigated or arbitrated in the appropriate fora.

  • Noye v. Johnson & Johnson Services, Inc., No. 18-2197 (3d Cir. Apr. 4, 2019)
    04/04/2019

    Court of appeals vacated lower court order denying defendant’s motion to compel arbitration, finding a sufficiently close relationship between defendant and the signatories to the arbitration agreement to allow defendant to enforce the agreement as a non-signatory.  The court found that a close relationship existed when, inter alia, a signatory was authorize to use the defendant’s logos and trademarks on employment forms including the document containing the arbitration agreement.

  • Egan Jones Ratings Company v. Pruette No. 17:3415 (3d Cir. Mar. 13, 2019)
    03/13/2019

    Court affirmed the district court decision denying to vacate a final partial arbitration award and granting cross-petition to confirm the award.  Court considered it is not proper for a reviewing court to reexamine the evidence when reviewing an arbitration award and errors in fact finding do not justify reversal and held the arbitrator’s findings were the result of proper weighing of conflicting evidence and no justifiable grounds for vacating the partial final award existed. 

  • Shore Point Distributing Company v. International Brotherhood of Teamsters Local 701 No. 17-3684 (3d Cir. Mar. 13, 2019)
    03/13/2019

    Court of appeals held it did not have jurisdiction to review an order that sent parties back to an arbitration that had already begun because pursuant to 9 USC § 16(b)(2) a court of appeals may not consider an appeal from an interlocutory order directing arbitration to proceed. 

  • Egan v. Live Nation Worldwide, Inc., No. 18-1794 (3d Cir. Mar. 6, 2019)
    03/06/2019

    Court of appeals vacated district court order’s denying defendant’s motion to compel arbitration and remanded the case for trial on the existence of an arbitration agreement.  Court found that the district court relied on an incorrect summary-judgement standard when it should have held a trial to resolve the dispute of material fact concerning whether plaintiff had agreed to the arbitration clause. 

  • Voorhees v. Tolia No. 18-1949 (3d Cir. Jan. 4, 2019)
    01/04/2019

    Court of appeals vacated the judgment of the district court and remanded for further proceedings.  Court held the district court did not address whether or why any of the plaintiff’s claims were subject to the arbitration agreement concluding it was not immediately apparent that all of them were. 

  • Neal v. Asta Funding, Inc., No. 17-1115 (3d Cir. Nov. 8, 2018)
    11/08/2018

    Court of appeals affirmed district court’s grant of summary judgment in favor of appellee in a dispute over the validity of an arbitration award in favor of appellee. In the arbitration proceedings, appellants argued that the claims against them were not arbitrable because they neither signed the agreement meant to contain the arbitration agreement and because the question of arbitrability must be resolved by a court, not the arbitrator. The arbitrator disagreed, finding that the appellants were subject to the arbitration agreement under a veil-piercing and alter-ego theory. The district court found the claims against appellants were arbitrable and granted summary judgment to appellee. Court of appeals affirmed, rejecting appellants’ arguments that the district court erred by applying federal law instead of state law and that the types of damages awarded against them were not authorized by the underlying agreements.

  • Ross Dress for Less Inc. v. VIWP, L.P., No. 17-3145 (3d Cir. Oct. 24, 2018)
     
    10/24/2018

    Court of appeals granted motion to confirm arbitration award pursuant to the FAA, holding that the AAA tribunal did not exceed its powers under § 10(a)(4) of the FAA or act in manifest disregard of Pennsylvania law in its application of the statute of limitations.  Court noted that because respondents failed to demonstrate the tribunal manifestly disregarded Pennsylvania law, it would not decide whether manifest disregard as an independent grounds for vacatur survives the Supreme Court’s decision in Hall Street Associates L.L.C. v. Mattel, Inc., 552 U.S. 576, 584 (2008).

  • Cook v. General Nutrition Corp., No. 17-3216 (3d Cir. Sept. 17, 2018)
    09/17/2018

    Court of appeals affirmed the district court’s order granting the motion to dismiss and compel arbitration.  Amongst other things, appellant argued that the district court erred by granting the motion to compel arbitration.  Court of appeals concluded that it was unable to consider this argument as the FAA limits appellate review to final orders.

  • Reading Health System v. Bear Sterns & Co., No. 16-4234 (3d Cir. Aug. 7, 2018)
    08/07/2018

    Court of appeals affirmed district court judgment compelling arbitration finding, inter alia, that forum selection clause did not waive right to arbitrate under FINRA Rule 12200.

  • Chuang v. OD Expense LLC, No. 17-1774 (3rd Cir. Aug. 01, 2018)
    08/01/2018

    Court of appeals affirmed district court’s denial of a motion to compel arbitration. Appellate court, reviewing de novo, agreed that defendants were not a party to the mandatory arbitration agreement they had sought to enforce, instead the arbitration provision defendant was party to permitted actions to be brought in Delaware.

  • Fin Associates LP v. Hudson Specialty Insurance Company, No. 16-3541 (3d Cir. July 25, 2018)
    07/25/2018

    Court granted motion to compel arbitration and stayed proceedings pending arbitration. Pursuant to the FAA, court found all prerequisites to arbitration had been met and plaintiffs’ claim for compensatory damages fell within the scope of the agreement. Court determined that plaintiff consented to the arbitral agreement through his attorney-in-fact, the agreement was not unconscionable, and defendant did not waive its right to arbitrate.

  • Clientron Corp. v. Devon It, Inc., No. 16-3432 (3d Cir. July 5, 2018)
    07/05/2018

    Court of appeals vacated district court’s order holding defendants liable for the breach of contract damages and monetary sanctions in relation to an award rendered by the Chinese Arbitration Association. Court determined that plaintiffs’ evidence was insufficient to pierce the corporate veil and that it would not pierce the veil on the basis of discovery sanctions.

  • ACE American Insurance Company v. Guerriero, No. 17-2893 (3d Cir. June 20, 2018)
    06/20/2018

    Court of appeals affirmed district court’s order granting motion to compel arbitration, finding the arbitration agreement to be valid and enforceable.

  • MacDonald v. Cashcall Inc., No. 17-2161 (D. Md. Feb. 27, 2018)
    02/27/2018

    Court of appeals affirmed district court’s denial of defendants’ motion to compel arbitration.  Court found that the arbitration agreement, including the delegation clause, was unenforceable because the agreement directed arbitration to an illusory forum and the forum selection clause was an integral, non-severable part of the arbitral agreement.

  • Edmondson v. Lilliston Ford Inc, No. 17-1991 (3d Cir. Jan. 11, 2018)

    01/11/2018

    Court of appeals affirmed district court order denying motion to vacate an arbitral award and granting cross-motion to confirm the award, finding that the arbitration clause’s validity was not affected by a business’s statement that it had “severed its ties with the AAA” or its failure to register the arbitration clause with the AAA prior to the filing of a demand for arbitration.

  • Crystallex International Corp v. Petroleos de Venezuela SA, No. 16-4012 (3rd Cir. Jan. 3, 2018)
    01/03/2018

    Court of appeals reversed and remanded a Delaware district court decision that a subsidiary of Petroleos de Venezuela SA, a non-debtor to an ICSID award against the Bolivarian Republic of Venezuela, was liable under the Delaware Uniform Fraudulent Transfer Act’s (DUFTA).  Court held that while the transfer resulted in assets being put out of the reach of creditors by virtue of international law, a transfer from a non-debtor, the subsidiary of Petroleos de Venezuela SA, to a debtor, Venezuela, is not covered by DUFTA.

  • Corchado v. Foulke Management Corp., No. 17-1433 (3d Cir. Dec. 21, 2017)
    12/21/2017

    Court of appeals affirmed the district court’s denial of appellant’s motion to compel arbitration, finding that appellees’ defense of fraudulent inducement to sign the arbitration agreement was sufficient grounds for the district court to deny the motion to compel arbitration.

  • Anoruo v. Tenet Healthsystem Hanhemann, DBA Hahnemann University Hospital, No. 17-1945 (3d Cir. Sept. 19, 2017)
    09/19/2017

    Court of appeal affirmed district court’s order granting defendant’s motion to confirm an arbitration award and denying plaintiff’s motion to vacate that award.  Circuit court held that the appellant failed to establish any basis to vacate the arbitrator’s ruling.

  • White v. Sunoco, Inc., No. 16-2808 (3d Cir. Sept. 5, 2017)
    09/05/2017

    Court affirmed decision to deny motion to compel arbitration, holding that defendant, as a non-signatory to the arbitration agreement, could not compel plaintiff to arbitrate.  Court held that the principles of equitable estoppel could not be invoked since there was no alleged concerted conduct on the part of defendant and a signatory party.  Court also found that the claims asserted against defendant did not rely on any terms in the contract containing the arbitration agreement.

  • Employer Trustees of Western Pennsylvania Teamsters v. Union Trustees of Western Pennsylvania Teamsters, No. 16-3359 (3d Cir. Aug. 31, 2017)
    08/31/2017

    Court of appeal reversed district court’s denial of petition to appoint arbitrator, finding that the district erred in finding that a contested right was not provided for in the contract and thus not subject to arbitration, since the interpretation of the contract was a matter for the arbitrator to determine.

  • Chassen v. Fidelity National Financial Inc., No. 15-2814 (3rd Cir. Aug. 3, 2017)
    08/03/2017

    Court of appeal affirmed district court’s denial of defendant’s motion to compel arbitration.  Circuit court agreed that plaintiffs had not consented to arbitration when they signed an owner’s policy that included an arbitration provision that was later amended to require both parties to consent to arbitration before arbitration could be compelled.  Court rejected appellant’s arguments that the amendment to the arbitration agreement had resulted from mutual mistake or that it should not apply because two agreements at issue were not incorporated.

  • McHale v. Taylored Services, LLC, No. 16 -3196 (3d Cir. July 12, 2017)
    07/12/2017

    Court of appeals reversed district court’s modification adding attorney’s fees to an arbitration award, reasoning that a court has very limited authority to vacate or modify an arbitration award.

     

  • McHale v. Taylored Services, LLC, No. 16-3196 (3d Cir. July 12, 2017)
    07/12/2017

    Court of appeal reversed district court’s modification of an arbitration award to grant appellee attorney’s fees.  Court held that under New Jersey law, absent an agreement by the parties to expand judicial review, a court could only modify an award if the arbitrator made an award on a claim not submitted to the arbitrator.  Court held that the arbitrator had reviewed the issues properly before it when it concluded that neither party prevailed more than the other to award attorney’s fees to appellee, and that, at most, the conclusion was an error of law unreviewable by the district court. 

  • Silfee v. Automatic Data Processing, Inc., No. 16-3725 (3d Cir. June 13, 2017)
    06/13/2017

    Court of appeals vacated and remanded the district court’s prior order denying motions to compel arbitration and dismiss the suit. Court held that since arbitrability is a gateway issue under §4 of the FAA, if a party moves to compel arbitration based on an authentic arbitration agreement that is attached to the complaint, a Rule(b)(6) summary judgment standard is appropriate unless the other party responds with additional facts sufficient to place the agreement to arbitrate at issue. Here, there were no facts presented at the outset of the litigation to place the arbitration agreement at issue and therefore the lower court failed to analyze the parties’ competing arguments regarding arbitrability.

  • Benhenni v. Bayesian Efficient Strategic Trading, LLC, No. 16-3949 (3d Cir. June 5, 2017)
    06/05/2017

    Court of appeal affirmed the district court’s denial of pro se appellant’s petition to vacate an arbitral award. Court found that appellant filed a non-compliant appellate brief devoid of references to the record and citations to legal authority in support of his arguments, which failed to identify why the district court’s order should be disturbed. Court also found that appellant’s arguments amounted to assertions that the arbitrator’s interpretation was flawed, a basis upon which the court could not vacate the arbitrator’s award.

  • Robredo v. Metro Honda, No. 16-3317 (3d Cir. May 26, 2017)
    05/26/2017

    Court of appeal affirmed district court’s grant of summary judgment in favor of defendant, finding that the parties agreed to arbitrate all claims arising out of or relating to automobile purchase/lease transactions and the evidence did not support plaintiff’s claims that the arbitration proceedings were unfair or biased. 

  • Jones v. SCO Silver Care Operations LLC, No. 16-1101 (3d Cir. May 18, 2017)
    05/18/2017

    Court of appeals affirmed decision denying motion to dismiss or to stay proceedings pending arbitration, holding that the collective bargaining agreement did not provide a clear and unmistakable waiver of the right to judicial recourse for statutory claims, and that neither of the claims depended on interpretation of the agreement.  Court found plaintiffs’ claims were based on statutory and factual analysis, and did not depend on a disputed term of the contract.

  • Horton v. FedChoice Federal Credit Union, No. 16-3960 (3d Cir. May 2, 2017)
    05/02/2017

    Court of appeal affirmed denial of motion to dismiss or stay in favor of arbitration, finding that the district court did not err in determining that the complaint and incorporated documents are not clear on their face as to an agreement to arbitrate, and thus that the non-movant is entitled to conduct limited discovery on the narrow issue concerning the validity of the arbitration agreement.

  • Novosad v. Broomall Operating Company LP, No. 16-2089 (3d Cir. Apr. 10, 2017)
    04/10/2017

    Court of appeals affirmed lower court’s judgment holding that an arbitration clause that covered “only claims by individuals and [did] not cover class or collective actions” excluded a putative class and collective action for overtime pay from arbitration.  Court found that despite a strong federal policy favoring arbitration, in this case, the arbitration clause unmistakably excluded class and collective actions from mandatory arbitration.

  • James v. Global Tellink Corp., No. 16-1555 (3d Cir. Mar. 29, 2017)
    03/29/2017

    Circuit court affirmed district court ruling denying motion to compel arbitration against plaintiff and putative class.  Circuit court held that appellees did not agree to arbitrate their dispute with appellants and a party cannot be required to arbitrate without consent.

  • Aliments Krispy Kernels, Inc. v. Nichols Farms, No. 16-1975 (3d Cir. Mar. 21, 2017)
    03/21/2017

    Court of appeals vacated district court’s judgment denying plaintiff’s petition to confirm an arbitration award and granted defendant’s petition to vacate the award.  Court found that issues of material fact existed as to whether the parties agreed to engage in arbitration proceedings, which defendant refused to attend. Court remanded the case to the district court for further proceedings.

View All