GE Energy Power Conversion France SAS v. Outokumpu Stainless USA, LLC
View Official PDFBelow are plain-language sections to help you understand what the Court decided in GE Energy Power Conversion France SAS v. Outokumpu Stainless USA, LLC and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of GE Energy Power Conversion France SAS v. Outokumpu Stainless USA, LLC.
The Supreme Court addressed whether the New York Convention conflicts with domestic equitable estoppel doctrines that allow nonsignatories to enforce arbitration agreements. The Court found that the Convention does not preclude such enforcement, as it is silent on nonsignatory enforcement and does not exclude domestic doctrines. The case was reversed and remanded for further proceedings on whether GE Energy can enforce the arbitration clauses under equitable estoppel principles.
Holding
The single most important “bottom line” of what the Court decided in GE Energy Power Conversion France SAS v. Outokumpu Stainless USA, LLC.
The Court held that the New York Convention does not conflict with domestic equitable estoppel doctrines that permit nonsignatories to enforce arbitration agreements.
Constitutional Concepts
These are the Constitution-related themes that appear in GE Energy Power Conversion France SAS v. Outokumpu Stainless USA, LLC. Click a concept to see other cases that involve the same idea.
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Why Preemption is relevant to GE Energy Power Conversion France SAS v. Outokumpu Stainless USA, LLC
The case involves the interaction between domestic law and an international treaty, examining whether domestic equitable estoppel doctrines conflict with the New York Convention.
Syllabus excerpt (verbatim)The New York Convention does not conflict with domestic equitable estoppel doctrines that permit the enforcement of arbitration agreements by nonsignatories.
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Why Judicial Review is relevant to GE Energy Power Conversion France SAS v. Outokumpu Stainless USA, LLC
The Court reviewed the interpretation of the New York Convention and its application to domestic law, which involves judicial review of treaty interpretation.
Syllabus excerpt (verbatim)The application of familiar tools of treaty interpretation establishes that the state-law equitable estoppel doctrines permitted under Chapter 1 do not 'conflict with . . . the Convention.'
Key Quotes
Short excerpts from the syllabus in GE Energy Power Conversion France SAS v. Outokumpu Stainless USA, LLC that support the summary and concepts above.
The New York Convention does not conflict with domestic equitable estoppel doctrines.
The Convention is simply silent on the issue of nonsignatory enforcement.
The text of the New York Convention does not address whether nonsignatories may enforce arbitration agreements under domestic doctrines such as equitable estoppel.
