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contractlawsuitarbitrationstatuteappealtrustcorporationantitrustarbitration clause
contractlawsuitarbitrationappealtrustcorporationantitrustarbitration clause

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Mitsubishi Motors Corp. v. Soler Chrysler-Plymouth, Inc., 473 U.S. 614, 105 S.Ct. 3346, 87 L.Ed.2d 444, 53 USLW 5069, 1985-2 Trade Cases P 66,669

Facts

Mitsubishi Motors Corporation, a Japanese automobile manufacturer, entered into a distribution agreement with Soler Chrysler-Plymouth, Inc., a Puerto Rico corporation. The agreement included an arbitration clause for disputes arising from the contract. After Soler faced difficulties in meeting sales targets, Mitsubishi withheld shipments of vehicles, leading to a lawsuit by Mitsubishi to compel arbitration. Soler counterclaimed, alleging violations of antitrust laws and other statutes. The District Court ordered arbitration of most claims, including antitrust claims, which Soler appealed.

Mitsubishi Motors Corporation, a Japanese automobile manufacturer, entered into a distribution agreement with Soler Chrysler-Plymouth, Inc., a Puerto Rico corporation. The agreement included an arbitration clause for disputes arising from the contract. After Soler faced difficulties in meeting sales targets, Mitsubishi withheld shipments of vehicles, leading to a lawsuit by Mitsubishi to compel arbitration.

Issue

The main legal issue was whether the antitrust claims raised by Soler were arbitrable under the Federal Arbitration Act despite the general presumption against arbitration of statutory claims.

The principal question presented by these cases is the arbitrability, pursuant to the Federal Arbitration Act, 9 U.S.C. § 1 et seq., and the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (Convention), of claims arising under the Sherman Act, 15 U.S.C. § 1 et seq., and encompassed within a valid arbitration clause in an agreement embodying an international commercial transaction.

Rule

The Supreme Court ruled that arbitration agreements should be enforced according to their terms, and that the Federal Arbitration Act favors arbitration of statutory claims unless there is a clear indication that Congress intended to preclude arbitration for those claims.

The Arbitration Act establishes that, as a matter of federal law, any doubts concerning the scope of arbitrable issues should be resolved in favor of arbitration, whether the problem at hand is the construction of the contract language itself or an allegation of waiver, delay, or a like defense to arbitrability.

Analysis

The Court analyzed the arbitration clause in the context of the Federal Arbitration Act and the Convention on the Recognition and Enforcement of Foreign Arbitral Awards. It found that the clause encompassed the statutory claims raised by Soler, including antitrust claims, and that the international nature of the transaction warranted enforcement of the arbitration agreement. The Court rejected the argument that antitrust claims are inherently nonarbitrable, emphasizing the need for predictability in international commerce.

The Court analyzed the arbitration clause in the context of the Federal Arbitration Act and the Convention on the Recognition and Enforcement of Foreign Arbitral Awards. It found that the clause encompassed the statutory claims raised by Soler, including antitrust claims, and that the international nature of the transaction warranted enforcement of the arbitration agreement.

Conclusion

The Supreme Court affirmed in part and reversed in part the decision of the Court of Appeals, holding that the antitrust claims were subject to arbitration under the Federal Arbitration Act.

The Supreme Court affirmed in part and reversed in part the decision of the Court of Appeals, holding that the antitrust claims were subject to arbitration under the Federal Arbitration Act.

Who won?

Mitsubishi Motors Corporation prevailed in the case because the Supreme Court upheld the enforceability of the arbitration clause, allowing the antitrust claims to be arbitrated.

Mitsubishi Motors Corporation prevailed in the case because the Supreme Court upheld the enforceability of the arbitration clause, allowing the antitrust claims to be arbitrated.

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