Eickhoff Corporation v. Warrior Met Coal, LLC

Summary

The court held that the parties' incorporation of the AAA Commercial Arbitration Rules clearly and unmistakably delegated arbitrability questions to the arbitrator. Because Warrior Coal's warranty, contract, and products-liability claims were at least arguably connected to the master service agreements, the trial court erred by deciding that the claims were outside the arbitration provision and denying Eickhoff's motion. Justice Parker, dissenting, would have held that a general reference to the AAA rules did not clearly and unmistakably authorize an arbitrator to decide arbitrability.