Who decides arbitration disputes
Henry Schein v. Archer & White Sales
In brief
The Court rejected the “wholly groundless” exception and sent the case back to the Fifth Circuit.
- Where it stands
- Decided
Decided 9-0 · January 8, 2019 · Opinion by Justice Kavanaugh
- What it’s about
- In Henry Schein’s dispute with Archer & White, the Supreme Court ruled that the Federal Arbitration Act does not let a court reject an agreement assigning an arbitrator the question of whether a dispute must be arbitrated merely because the court considers the argument for arbitration baseless.
- Who it affects
- Courts cannot use the “wholly groundless” exception when an agreement assigns an arbitrator to decide whether a dispute must be arbitrated.
Summary: written with AI from the case record.
What it's about
It wiped out the Fifth Circuit’s ruling and sent the case back to that court (vacated and remanded).
Henry Schein and Archer & White Sales disputed whether a court or an arbitrator should decide if their dispute had to go to arbitration.
The Fifth Circuit had applied a rule letting courts reject an argument that a dispute belonged in arbitration if the court thought the argument baseless.
Question presented
Whether the Federal Arbitration Act permits a court to decline to enforce an agreement?
What the Court decided
Holding
The “wholly groundless” exception to arbitrability is inconsistent with the Federal Arbitration Act and this Court’s precedent. Under the Act, arbitration is a matter of contract, and courts must enforce arbitration contracts according to their terms. Rent-A-Center, West, Inc. v. Jackson , 561 U. S. 63, 67. The parties to such a contract may agree to have an arbitrator decide not only the merits of a particular dispute, but also “ ‘gateway’ questions of ‘arbitrability.’ ” Id. , at 68– 69. 878 F. 3d 488, vacated and remanded.
- Result
- Vacated
The Court's reasoning
The Court said arbitration agreements are contracts, so courts must enforce them according to their terms. Parties can assign an arbitrator the threshold question of whether a dispute belongs in arbitration, and a court cannot bypass that assignment by calling the argument for arbitration baseless.
The vote
What's next
The Fifth Circuit must reconsider the dispute under the Supreme Court’s ruling.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Opinion added: opinion
Brief added: Petition
Brief added: Reply
Brief added: Questions Presented
More questions
- Did the Court decide whether this dispute had to be arbitrated?
- No. It ruled on the “wholly groundless” exception, not whether this particular dispute had to go to 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.