Stolt-Nielsen S.A. v. AnimalFeeds International Corp.
United States Supreme Court
559 U.S. 662 (2010)
After the Justice Department found Stolt-Nielsen (defendant) engaged in illegal price-fixing, AnimalFeeds (plaintiff), which had shipped goods under Stolt-Nielsen's standard maritime charter-party agreement, demanded class arbitration despite the agreement being silent on class treatment. A three-arbitrator panel, agreed to by both parties, found the arbitration clause allowed class arbitration; the district court vacated that award for disregarding maritime law, but the court of appeals reversed, finding no manifest disregard since Stolt-Nielsen cited no authority against class arbitration under maritime custom-and-usage. The Supreme Court granted certiorari.
Whether a party may be compelled under the Federal Arbitration Act to submit to class arbitration if there is no contractual basis for concluding that the party agreed to do so in the arbitration agreement.