Smith v. Spizzirri, 601 U.S. 472 (2024); Coinbase, Inc. v. Suski, 144 S. Ct. 1186 (2024)

In Smith, the Court held that under Section 3 of the Federal Arbitration Act, when a federal court determines that a dispute is subject to arbitration, and a party requests a stay of the court proceeding pending arbitration, Section 3 compels the court to issue a stay, and the court lacks the discretion to dismiss the suit pending the outcome of the arbitration. Per the Court, Section 3 “overrides any discretion a district court might otherwise have had to dismiss a suit when the parties have agreed to arbitration.” In Coinbase, the Court held that when parties rely on two inconsistent documents, one which states that disputes under the contract are arbitrable, and the other stating that all disputes under the contract must be decided by a court, a court must decide which document controls. The issue arose because Coinbase’s user agreement broadly calls for arbitration, but Coinbase also offered a sweepstakes for users to win the cryptocurrency “Dogecoin.” The rules of the sweepstakes provided that each entrant in the sweepstakes must submit to the jurisdiction of California courts. The Court held that “a court, not an arbitrator” must decide whether the sweepstakes rules superseded the user agreement.