Supreme Court of the United States
Ge Energy Power Conversion France Sas, Corp., Fka Converteam Sas, Petitioner v. Outokumpu Stainless USA, LLC
June 1, 2020590 U.S. 432
Summary
Justice Thomas, writing for a unanimous Court, held that the New York Convention does not conflict with domestic equitable estoppel doctrines permitting nonsignatories to enforce arbitration agreements. Article II imposes recognition and enforcement obligations without excluding additional grounds for enforcement under domestic law. The Court reversed and remanded, leaving unresolved whether GE Energy could establish equitable estoppel and which body of law governed that determination. Justice Sotomayor concurred separately, without any justice joining her opinion, emphasizing that domestic nonsignatory doctrines must respect the Federal Arbitration Act’s requirement of consent to arbitration and suggesting that the contracts might expressly cover GE Energy as a subcontractor.
Holding
- Whether the New York Convention precludes enforcement of arbitration agreements by nonsignatories under domestic equitable estoppel doctrines.. The New York Convention does not conflict with domestic equitable estoppel doctrines permitting nonsignatories to enforce arbitration agreements.
Docket 18-1048
Cited authorities
- CA11
- agreement
- agreement
- New York Convention
- agreement
- agreement
- agreement
- New York Convention
Cited by
- FWK Holdings LLC v. Shire PLC (Direct Purchaser Antitrust Class Action Complaint)
- Symonds v. Credico (USA) LLC
- Al-Qarqani v. Arab American Oil Company
- Aguasvivas v. Pompeo
- Cathay Capital Holdings II, LP v. Zheng
- Spanish Villa, LLC v. Certain Underwriters at Lloyd's London
- Landbridge Port Services (Hong Kong) Ltd. v. Zhang
- Cedar Ridge, LLC v. Certain Underwriters at Lloyds London