Eckert/Wordell Architects, Inc. v. FJM Properties of Willmar, LLC

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• concluding that whether an arbitration provision could be used to compel arbitration between a nonsignatory and a signatory was a threshold question of arbitrability subject to delegation
• holding that incorporation of the AAA rules into a contract 23 requiring arbitration is a clear and unmistakable indication that the parties intended for the arbitrator 24 to decide threshold questions of arbitrability
• holding that “whether a particular arbitration provision may be used to compel arbitration between a signatory and a nonsignatory is a threshold question of arbitrability,” which the arbitration agreement delegated to the arbitrator
• holding whether non-signatory could compel signatory to arbitrate was a question for the arbitrator because arbitration agreement incorporated AAA Rules, which delegated arbitrability to the arbitrator
• noting that incorporation of arbitration organization rules is a “clear and unmistakable indication [that] the parties intended for the arbitrator to decide threshold questions of arbitrability”
• affirming district court order compelling arbitration; where arbitration agreement incorporates AAA rules, it is for the arbitrator to determine if claims against non-signatory are arbitrable

Source: CourtListener parenthetical corpus (CC0).