Smith v. Spizzirri
View Official PDFSummary
A short, plain-English overview of Smith v. Spizzirri.
In Smith v. Spizzirri, the Supreme Court addressed the application of Section 3 of the Federal Arbitration Act (FAA), which mandates that courts must stay proceedings when a dispute is subject to arbitration, upon a party's request. The Court found that the District Court erred in dismissing the case without prejudice instead of staying it, as required by the statute. The Ninth Circuit's affirmation of the dismissal was reversed.
Holding
The single most important “bottom line” of what the Court decided in Smith v. Spizzirri.
The Court held that when a district court finds a lawsuit involves an arbitrable dispute and a party requests a stay, Section 3 of the FAA compels the court to issue a stay.
Key Quotes
Short excerpts from the syllabus in Smith v. Spizzirri that support the summary and concepts above.
The plain text of § 3 requires a court to stay the proceeding upon request.
The statute's use of the word 'shall' 'creates an obligation impervious to judicial discretion.'
Respondents' reading disregards the long-established legal meaning of the word 'stay' as a 'temporary suspension' of legal proceedings.
