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Smith v. Spizzirri

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Supreme Court of the United States
Smith v. Spizzirri
Term: 2023
Important Dates
Argued: April 22, 2024
Decided: May 16, 2024
Outcome
reversed and remanded
Vote
9-0
Majority
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett • Ketanji Brown Jackson

Smith v. Spizzirri is a case that was decided by the Supreme Court of the United States on May 16, 2024, during the court's October 2023-2024 term. The case was argued before the Supreme Court of the United States on April 22, 2024.

In a 9-0 opinion, the court reversed and remanded the judgment of the United States Court of Appeals for the Ninth Circuit, holding that when a district court finds that a lawsuit involves an arbitrable dispute, and a party requests a stay pending arbitration, §3 of the Federal Arbitration Act compels the court to stay the proceeding. Justice Sonia Sotomayor delivered the opinion of the court.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned Section 3 of the Federal Arbitration Act and adjudication of lawsuits while arbitration proceedings are ongoing. Click here to learn more about the case's background.
  • The questions presented: "Whether Section 3 of the FAA requires district courts to stay a lawsuit pending arbitration, or whether district courts have discretion to dismiss when all claims are subject to arbitration."[2]
  • The outcome: In a 9-0 opinion, the court reversed and remanded the judgment of the United States Court of Appeals for the Ninth Circuit, holding that when a district court finds that a lawsuit involves an arbitrable dispute, and a party requests a stay pending arbitration, §3 of the Federal Arbitration Act compels the court to stay the proceeding. Justice Sonia Sotomayor delivered the opinion of the court.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the Ninth Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    Background

    The petitioners—Wendy Smith, Michelle Martinez, and Kenneth Turner—are collectively referred to as "Smith" in the proceedings. Smith are current and former delivery drivers for on-demand delivery service Intelliserve LLC. The petitioners sued their employer—individual owners and managers collectively referred to as "Spizzirri"—in Arizona state court for violating federal and state employment laws. They allege that Spizzirri misclassified them as independent contractors, failed to pay require minimum and overtime wages; and failed to provide paid sick leave.[3][4][5]

    In U.S. District Court for the District of Arizona, Spizzirri moved to compel arbitration with Smith and for the court to dismiss the case. Smith argued that Section 3 of the Federal Arbitration Act required the District of Arizona to pause pending arbitration while the lawsuit was ongoing.[3][4][5]

    Section three of the FAA provides:[6]

    “ If any suit or proceeding be brought in any of the courts of the United States upon any issue referable to arbitration under an agreement in writing for such arbitration, the court in which such suit is pending, upon being satisfied that the issue involved in such suit or proceeding is referable to arbitration under such an agreement, shall on application of one of the parties stay the trial of the action until such arbitration has been had in accordance with the terms of the agreement, providing the applicant for the stay is not in default in proceeding with such arbitration.[7] ”

    The District of Arizona dismissed the lawsuit.[3][4][5]

    On appeal, a three-judge panel of the United States Court of Appeals for the Ninth Circuit—Judges Susan P. Graber, Mark J. Bennett, and Roopali Desai—affirmed the United States District Court for the District of Arizona ruling, holding:[3]

    “ Plaintiff delivery drivers sued their employer, an on-demand delivery service, alleging violation of various state and federal employment laws. The parties agreed that all claims are subject to mandatory arbitration. Accordingly, the district court granted Intelliserve's motion to compel arbitration, but also dismissed the lawsuit without prejudice. Plaintiffs argue that the district court should have stayed the action pending arbitration rather than dismissing it. We have jurisdiction under 28 U.S.C. § 1291, and we affirm.


    Defendants include individual owners and managers of Intelliserve LLC as well as related corporate entities. We refer to Defendants collectively as "Intelliserve," as the parties do in their briefing.

    The sole question before us is whether the Federal Arbitration Act ("FAA") requires a district court to stay a lawsuit pending arbitration, or whether a district court has discretion to dismiss when all claims are subject to arbitration. Although the plain text of the FAA appears to mandate a stay pending arbitration upon application of a party, binding precedent establishes that district courts may dismiss suits when, as here, all claims are subject to arbitration. Thus, we affirm.[7]

    		”

    On June 14, 2023, Smith et al. appealed to the U.S. Supreme Court to review the case.[4] On January 12, 2024, SCOTUS accepted the case to its merits docket for oral arguments.

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether Section 3 of the FAA requires district courts to stay a lawsuit pending arbitration, or whether district courts have discretion to dismiss when all claims are subject to arbitration.

    [7]

    		”

    Oral argument

    Audio

    Audio of oral argument:[8]




    Transcript

    Transcript of oral argument:[9]

    Outcome

    In a 9-0 opinion, the court reversed and remanded the judgment of the United States Court of Appeals for the Ninth Circuit, holding that when a district court finds that a lawsuit involves an arbitrable dispute, and a party requests a stay pending arbitration, §3 of the Federal Arbitration Act compels the court to stay the proceeding. Justice Sonia Sotomayor delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Sonia Sotomayor wrote:[1]

    “

    When a district court finds that a lawsuit involves an arbitrable dispute, and a party requests a stay pending arbitration, §3 of the FAA compels the court to stay the proceeding. The contrary judgment of the Court of Appeals is reversed, and the case is remanded for further proceedings consistent with this opinion.[7]

    		”
    —Justice Sonia Sotomayor

    Text of the opinion

    Read the full opinion here.

    October term 2023-2024

    See also: Supreme Court cases, October term 2023-2024

    The Supreme Court began hearing cases for the term on October 2, 2023. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[10]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 U.S. Supreme Court, "Smith v. Spizzirri," accessed May 17, 2024
    2. ↑ 2.0 2.1 U.S. Supreme Court, "22-1218 SMITH V. SPIZZIRRI," accessed January 16, 2024
    3. ↑ 3.0 3.1 3.2 3.3 3.4 U.S. Court of Appeals for the Ninth Circuit, Forrest v. Spizzirri, decided March 16, 2023
    4. ↑ 4.0 4.1 4.2 4.3 U.S. Supreme Court, "Smith v. Spizzirri ON PETITION FOR A WRIT OF CERTIORARI," filed June 14, 2023
    5. ↑ 5.0 5.1 5.2 Oyez, Smith v. Spizzirri, accessed February 28, 2024
    6. ↑ 9 U.S.C. § 3, "Section 3 - Stay of proceedings where issue therein referable to arbitration," accessed February 29, 2024
    7. ↑ 7.0 7.1 7.2 7.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    8. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued April 22, 2024
    9. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued April 22, 2024
    10. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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