State law in arbitration agreements
DIRECTV v. Imburgia
In brief
The Supreme Court ruled that the arbitration agreement must be enforced, overturning the California appeals court.
- Where it stands
- Decided
Decided 6-3 · December 14, 2015 · Opinion by Justice Breyer
- What it’s about
- Amy Imburgia brought a proposed class action against DIRECTV, alleging that its early-termination fees violated California law.
- Who it affects
- The California appeals court must enforce the arbitration agreement between Imburgia and DIRECTV.
Summary: written with AI from the case record.
What it's about
The Supreme Court overturned the California appeals court’s ruling and sent the case back (reversed and remanded), deciding that the Federal Arbitration Act preempts the court’s interpretation and requires enforcement of the arbitration agreement.
Imburgia alleged that DIRECTV's early-termination fees violated California consumer-protection laws, including the Consumers Legal Remedies Act.
The contract said its arbitration agreement would be unenforceable if state law did not permit agreements that bar class arbitration.
Question presented
Did the California Court of Appeal err in holding that a reference to state law in an arbitration clause required the application of that state law despite its preemption by the Federal Arbitration Act?
What the Court decided
Holding
Because the California Court of Appeal’s interpretation is pre - empted by the Federal Arbitration Act, that court must enforce the arbitration agreement. 225 Cal. App. 4th 338, 170 Cal. Rptr. 3d 190, reversed and remanded.
- Result
- Reversed
The Court's reasoning
The Court said the Federal Arbitration Act overrides the California appeals court's interpretation, so that court must enforce the arbitration agreement.
The vote
From the opinions
“I would read it, as the California court did, to give the customer, not the drafter, the benefit of the doubt.”
What's next
The dispute returns to the California Court of Appeal, which must enforce the agreement as the Supreme Court directed.
Documents
Opinions
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Opinion added: DIRECTV
More questions
- What was Justice Thomas's view of the Federal Arbitration Act?
- He believed it does not apply in state courts and therefore does not require them to order arbitration.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.