Supreme Court of the United States
Kpmg LLP v. Cocchi
November 7, 2011565 U.S. 18
Summary
The Supreme Court held that under the Federal Arbitration Act, courts must compel arbitration of arbitrable claims even when a complaint also contains nonarbitrable claims. It vacated the Florida Court of Appeal’s refusal to compel arbitration and remanded for further determination of the remaining claims.
Holding
- Whether the Federal Arbitration Act requires a court to compel arbitration of arbitrable claims when a complaint also contains nonarbitrable claims. Yes; the FAA mandates that courts compel arbitration of arbitrable claims even if the complaint contains nonarbitrable claims, and courts may not refuse arbitration on the basis of the nonarbitrable claims alone.
- Whether a district court may refuse to compel arbitration on the basis that some claims are nonarbitrable without addressing the arbitrable claims. No; the district court’s blanket refusal was erroneous because it failed to examine each claim individually as required by the FAA.
- What relief is appropriate when a lower court improperly refuses to compel arbitration of arbitrable claims. The appellate judgment is vacated and the case remanded for the lower court to determine arbitrability of the remaining claims and to compel arbitration where appropriate.
Docket 10-1521
Cited authorities
- 9 U.S.C. § 1
- Fla. Stat. §501.201
- 9 U.S.C. §2
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