Supreme Court of the United States

Nitro-Lift Technologies, L. L. C. v. Howard

November 26, 2012568 U.S. 17

Summary

The Supreme Court granted certiorari and held that the Oklahoma Supreme Court lacked jurisdiction because its decision was not based on independent state grounds and, under the Federal Arbitration Act, challenges to the validity of non‑competition agreements in contracts containing arbitration clauses must be decided by the arbitrator. Accordingly, the state court judgment was vacated and the case remanded for proceedings consistent with this opinion.

Holding

  • Whether the Oklahoma Supreme Court's decision was based on independent and adequate state grounds, thereby precluding Supreme Court jurisdiction.. The decision was not based on independent state grounds because it necessarily rejected the federal claim, so the Supreme Court has jurisdiction.
  • Whether the Federal Arbitration Act requires that challenges to the validity of the underlying contract, including non‑competition agreements, be decided by the arbitrator in the first instance.. Yes; under the FAA, such challenges are for the arbitrator, not the court.
  • Whether Oklahoma's specific statute limiting non‑competition agreements can override the general federal policy favoring arbitration under the Supremacy Clause.. No; the specific state statute does not displace the FAA, and the Supremacy Clause preempts the conflicting state law.

Docket 11-1377

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