Nitro-Lift Tech., L. L. C. v. Howard, 133 S. Ct. 500 (2012). · Go Syfert
Nitro-Lift Tech., L. L. C. v. Howard, 133 S. Ct. 500 (2012). Cases Citing This Book View Copy Cite
352 citation events (352 in the last 25 years) across 72 distinct courts.
Strongest positive: Ricky Hughes v. Wisconsin Central, Ltd. (ca8, 2024-06-25)
Treatment trajectory · 2012 → 2026 · click a year to view as-of
2012 2019 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) Ricky Hughes v. Wisconsin Central, Ltd.
8th Cir. · 2024 · signal: see · quote attribution · 1 verbatim quote · confidence high
he ancient interpretive principle that the specific governs the general (generalia specialibus non derogant) applies only to conflict between laws of equivalent dignity.
examined Cited as authority (verbatim quote) Coffman v. AT&T, Corp.
E.D. Ky. · 2023 · signal: see · quote attribution · 1 verbatim quote · confidence high
t is a mainstay of the act's substantive law that attacks on the validity of the contract, as distinct from attacks on the validity of the arbitration clause itself, are to be resolved 'by the arbitrator in the first instance, not by a federal or state court.
examined Cited as authority (verbatim quote) SIGNATURE LEASING LLC v. BUYER'S GROUP LLC (10×) also: Cited as authority (rule), Cited "see"
Okla. · 2020 · signal: see · quote attribution · 3 verbatim quotes · confidence high
hen state law prohibits outright the arbitration of a particular type of claim, the analysis is straightforward: the conflicting rule is displaced by the faa.
examined Cited as authority (quoted) Pulzone v. Kaleyra, INC.
E.D. Va. · 2023 · signal: see also · quote attribution · 1 verbatim quote · confidence low
hen parties commit to arbitrate contractual disputes, it is a mainstay of the substantive law that attacks on the validity of the contract . . . are to be resolved by the arbitrator in the first instance.
examined Cited as authority (quoted) MicroBilt Corp. v. Fidelity National Information Services, Inc. (In re MicroBilt Corp.) (2×)
Bankr. D.N.J. · 2012 · signal: see, e.g. · quote attribution · 2 verbatim quotes · confidence low
our cases hold that the faa forecloses precisely this type of 'judicial hostility towards arbitration.
cited Cited as authority (rule) Jordan Jones v. Credit One Bank, NA
N.D. Okla. · 2026 · confidence medium
Nitro-Lift Technologies, LLC v. Howard, 568 U.S. 17, 20-21 (2012); Arthur Andersen LLP v. Carlisle, 556 U.S. 624, 630 (2009).
discussed Cited as authority (rule) James Patterson v. Don Thornton Cadillac Inc. (2×) also: Cited "see"
N.D. Okla. · 2025 · confidence medium
Nitro-Lift Technologies, LLC v. Howard, 568 U.S. 17, 20-21 (2012); Arthur Andersen LLP v. Carlisle, 556 U.S. 624, 630 (2009).
discussed Cited as authority (rule) Vietti v. Welsh & McGough, PLLC
N.D. Okla. · 2025 · confidence medium
It is the Supreme Court’s responsibility “to say what a federal statute means, and once the Court has spoken, it is the duty of other courts to respect that understanding of the governing rule of law.” James v. City of Boise, 577 U.S. 306 , 307 (2016) (per curiam) (quoting Nitro-Lift Techs., L.L.C. v. Howard, 568 U.S. 17, 21 (2012) (per curiam) (quoting Rivers v. Roadway Express, Inc., 511 U.S. 298, 312 (1994))).
discussed Cited as authority (rule) Dieffenbach v. Upgrade, Inc.
M.D. Penn. · 2025 · confidence medium
In Chilutti, the | court invalidated the arbitration clause because it did not have the jury waiver | prominently displayed, not because of fraud, duress, or unconscionability. | Moreover, the United States Supreme Court has held that state courts “must abide by the FAA, which is 'the supreme Law of the Land,' U.S. Cons, ART. | [V, cl. 2, and by the opinions of this Court interpreting that law." Nitro-lift Tech., | LLC v. Howard, 568 U.S. 17, 21 (2012).
discussed Cited as authority (rule) Exencial Wealth Advisors, LLC v. Downing
N.C. Bus. Ct. · 2025 · confidence medium
Stat. § 219A] provides that “any” provision in a contract between the employer and employee conflicting with those terms “shall be void and unenforceable.” The term “any” is all-embracing and means nothing 41 The United States Supreme Court reversed the Oklahoma Supreme Court’s decision in Howard on grounds unrelated to the merits of the dispute, finding that it was for “the arbitrator to decide in the first instance whether the covenants not to compete are valid as a matter of applicable state law.” Nitro-Lift Techs., L.L.C. v. Howard, 568 U.S. 17, 22 (2012). 42 Prior to Ho…
discussed Cited as authority (rule) Bradford v. U.S. Department of Labor
10th Cir. · 2024 · confidence medium
Thus, this is not a case where we must apply “the well-established principle that, when two statutes conflict, the ‘specific governs the general.’” R-S-C v. Sessions, 869 F.3d 1176, 1184 (10th Cir. 2017) (emphasis added) (quoting Nitro-Lift Techs., LLC v. Howard, 568 U.S. 17, 21 (2012)).
discussed Cited as authority (rule) Kaiser v. Imperial Oil of North Dakota, Inc.
D. Mont. · 2024 · confidence medium
It only rejected the argument that the “trustee’s claims were barred by the statute of limitations under [] §§ 28-01-16 and 59-18-05(3).” Id. 65 long as the laws are of “equivalent dignity.” Nitro-Lift Techs, L.L.C. v. Howard, 568 U.S. 17, 21 (2012).
cited Cited as authority (rule) Taylor v. AAON, Inc.
N.D. Okla. · 2023 · confidence medium
Nitro-Lift Technologies, LLC v. Howard, 568 U.S. 17, 20-21 (2012); Arthur Andersen LLP v. Carlisle, 556 U.S. 624, 630 (2009).
discussed Cited as authority (rule) Mecke v. Bluegreen Vacations Corporation
W.D. Mo. · 2023 · confidence medium
Not only does the FAA require the enforcement of arbitration agreements, but it “declare[s] a national policy favoring arbitration.” Nitro-Lift Techs., L.L.C. v. Howard, 568 U.S. 17, 20 (2012) (quoting Southland Corp. v. Keating, 465 U.S. 1, 10 (1984)).
cited Cited as authority (rule) J.R. Filanc Construction Company, Inc. v. Town of Lyons
D. Colo. · 2022 · confidence medium
Indeed, “[s]tate courts rather than federal courts are most frequently called upon to apply the Federal Arbitration Act.” Nitro-Lift Techs., L.L.C. v. Howard, 568 U.S. 17, 17 (2012).
discussed Cited as authority (rule) Leddy v. Becerra
E.D.N.Y · 2022 · confidence medium
This conclusion derives from well-established principles of statutory interpretation. “[T]he ancient interpretive principle that the specific governs the general (generalia specialibus non derogant) applies … to conflict between laws of equivalent dignity.” Nitro-Lift Techs., L.L.C. v. Howard, 568 U.S. 17, 21 (2012).
cited Cited as authority (rule) McIntosh Transport, LLC v. Love's Travel Stops & Country Stores, Inc. and Empire Truck Sales, LLC
Miss. Ct. App. · 2022 · confidence medium
L.L.C. v. Howard, 568 U.S. 17, 20-21 (2012)). ¶9.
cited Cited as authority (rule) JP&G LLC d/b/a Orkin f/k/a JRGT LLC v. James Voss and Candy Voss
Miss. Ct. App. · 2021 · confidence medium
L.L.C. v. Howard, 568 U.S. 17, 20-21 (2012) (quoting Preston v. Ferrer, 552 U.S. 346, 349 (2008)).
discussed Cited as authority (rule) Changji Esquel Textile Co. Ltd. v. Raimondo
D.D.C. · 2021 · confidence medium
Furthermore, the Court’s construction does not violate the “ancient interpretive principle” that “the specific governs the general,” see Nitro-Lift Techs., LLC v. Howard, 568 U.S. 17, 21 (2012); see also Pls.’ Reply at 8, because § 4813(a)(2) does not impose a restriction on the defendants’ ability to establish and maintain lists for other reasons under the ECRA, see 50 14 U.S.C. § 4813 (a)(2).
discussed Cited as authority (rule) James v. Menard, Inc.
W.D. Mo. · 2021 · confidence medium
Not only does the FAA require the enforcement of arbitration agreements, but it “declare[s] a national policy favoring arbitration.” Nitro-Lift Techs., L.L.C. v. Howard, 568 U.S. 17, 20 (2012) (quoting Southland Corp. v. Keating, 465 U.S. 1, 10 (1984)).
discussed Cited as authority (rule) Woolridge v. Select Genetics, LLC
W.D. Mo. · 2021 · confidence medium
Not only does the FAA require the enforcement of arbitration agreements, but it “declare[s] a national policy favoring arbitration.” Nitro-Lift Techs., L.L.C. v. Howard, 568 U.S. 17, 20 (2012) (quoting Southland Corp. v. Keating, 465 U.S. 1, 10 (1984)).
discussed Cited as authority (rule) Villarreal-Dancy v. United States Department of the Air Force
D.D.C. · 2021 · confidence medium
Broadly speaking, an “ancient interpretive principle” dictates that “the specific governs the general (generalia specialibus non derogant).” Nitro-Lift Techs., L.L.C. v. Howard, 568 U.S. 17, 21 (2012); see also Ex parte Crow Dog, 109 U.S. 556, 570 (1883).
discussed Cited as authority (rule) Aci Technologies, Inc v. United States
Fed. Cl. · 2021 · confidence medium
The mistake made by the agency was not its determination that Andrea’s product complied with the solicitation, but rather its assumption that the Army had 1 This canon is known as “generalia specialibus non derogant.” See Nitro-Lift Techs., L.L.C. v. Howard, 568 U.S. 17, 21 (2012); Anchor Sav.
cited Cited as authority (rule) Langer Juice Company, Inc v. Zucarmex USA
C.D. Cal. · 2021 · confidence medium
Gunn v. Minton, 568 U.S. 17 251 (2013).
discussed Cited as authority (rule) TruGreen Limited Partnership v. Oklahoma Landscape, Inc.
N.D. Okla. · 2021 · confidence medium
Stat. §219A, which the Oklahoma Supreme Court has held “is the Legislature’s pronouncement on Oklahoma’s public policy regarding covenants not to compete.” Howard v. Nitro-Lift Techs., L.L.C., 273 P.3d 20, 28 (Okla. 2011) (reversed on other grounds by Nitro-Lift Techs., L.L.C. v. Howard, 568 U.S. 17, 133 (2012)).
discussed Cited as authority (rule) Auguste v. Synchrony Bank
S.D. Ohio · 2020 · confidence medium
As such, determined only that the arbitration provision was valid, leaving the parties to resolve their dispute in the arbitration setting. , 568 U.S. 17, 21 (2012) (although the validity of the arbitration provision “is subject to initial court determination . . .the validity of the remainder of the contract (if the arbitration provision is valid) is for the arbitrator to decide.”). 5“The Arbitrator, and not any court or agency, shall have exclusive authority to resolve any dispute relating to the applicability, interpretation, formation or enforceability of this Agreement including, bu…
discussed Cited as authority (rule) AF Trucking Inc v. Business Financial Services, Inc.
S.D.N.Y. · 2020 · confidence medium
Plaintiffs here do not make any challenge to the delegation clause, and thus the Court must leave the determination of whether the contract as a whole is valid “to the arbitrator in the first instance.” Nitro-Lift Techs., L.L.C. v. Howard, 568 U.S. 17, 18 (2012) (per curiam).
discussed Cited as authority (rule) Scarso Enterprises, Inc. v. Honor Yoga Management, LLC
N.D. Ohio · 2020 · confidence medium
Appx. 702, 706 (6th Cir. 2005) (determining enforceability of arbitration agreement under Ohio contract law). 33 Doc. 18 at 1, 3-5. 34 388 U.S. 395 , 403–04 (1967); , 568 U.S. 17, 20-21 (2012); , 546 U.S. 440, 444 (2006); , 748 F.3d 281 , 288–89 (6th Cir. 2014) (recognizing that the presumption in favor of arbitration extends even to attacks on the validity of the contract as a whole and that only questions going to the “formation” of the arbitration clause itself—i.e., whether the parties ever agreed to the arbitration clause in the first place-are for the courts to decide); , 288 F…
discussed Cited as authority (rule) Marine Development, Inc. v. Huffman Construction, LLC
N.D. Okla. · 2020 · confidence medium
Nitro-Lift Technologies, LLC v. Howard, 568 U.S. 17, 20-21 (2012); Arthur Andersen LLP v. Carlisle, 556 U.S. 624, 630 (2009). 3 A motion to compel arbitration calls for a two-step inquiry concerning the arbitrability of the dispute: (1) whether there is a valid arbitration agreement, and (2) whether the particular dispute falls within the scope of that agreement.
cited Cited as authority (rule) Dowe v. Prudential Financial Inc.
S.D.N.Y. · 2019 · confidence medium
Corp. v. Lewis, 138 S. Ct. 1612, 1621 (2018); Nitro–Lift Techs., L.L.C. v. Howard, 568 U.S. 17, 20 (2012); Rent-A-Center, West, Inc. v. Jackson, 561 U.S. 63, 67 (2010).
discussed Cited as authority (rule) Anytime Labor-Kansas LLC v. Anderson
W.D. Mo. · 2018 · confidence medium
Declaratory Judgment The Federal Arbitration Act (the “FAA”), 9 U.S.C. § 1 et seq., “declare[s] a national policy favoring arbitration.” Nitro-Lift Techs., L.L.C. v. Howard, 133 S. Ct. 500, 503 (2012) (citation omitted).
discussed Cited as authority (rule) Tedesco v. Home Savings Bancorp, Inc.
Mont. · 2017 · confidence medium
“IHinder the FAA, when a party challenges the validity of a contract as a whole, an arbitrator should resolve that dispute in the first instance.” Kelker, ¶ 12 (citing Nitro-Lift Techs., L.L.C. v. Howard, 568 U.S. 17, 20 , 133 S. Ct. 500, 503 (2012)); accord Martz v. Beneficial Mont., Inc., 2006 MT 94, ¶ 17 , 332 Mont. 93 , 135 P.3d 790 (“[AJrbitration, not court, is the proper forum for challenges to contracts as a whole where those contracts contain arbitration provisions.”).
discussed Cited as authority (rule) NAJERA v. DAVID STANLEY CHEVROLET (2×)
Okla. Civ. App. · 2017 · confidence medium
Accordingly, Walker is inapplicable here." Mooneyham , 682 F. App'x at 662. 5 Of course, "it is a mainstay of the [Federal Arbitration] Act's substantive law that attacks on the validity of the contract, as distinct from attacks on the validity of the arbitration clause itself , are to be resolved by the arbitrator in the first instance, not by a federal or state court." Nitro-Lift Techs., L.L.C. v. Howard , 568 U.S. 17, 20-21 (2012) (per curiam) (emphasis added) (internal quotation marks omitted) (citations omitted). 6 See also State ex rel.
discussed Cited as authority (rule) Smith v. D.R. Horton, Inc
S.C. · 2016 · confidence medium
Indeed, absent a "discreet challenge to the validity of the arbitration clause," federal law establishes that challenges to the validity of contractual provisions "are within the arbitrator's ken." Preston, 552 U.S. at 353– 54. "[W]hen parties commit to arbitrate contractual disputes, it is a mainstay of the [FAA]'s substantive law that attacks on the validity of the contract, as distinct from attacks on the validity of the arbitration clause itself, are to be resolved by the arbitrator in the first instance . . . ." Nitro-Lift Techs., LLC, v. Howard, 133 S.Ct. 500, 503 (2012) (internal quot…
discussed Cited as authority (rule) Matter of Monarch Consulting, Inc v. National Union Fire Insurance Company of Pittsburgh, PA
NY · 2016 · confidence medium
As the United States Supreme Court has stated, *675 “[Challenges to the validity of arbitration agreements . . . can be divided into two types,” namely, “challenges specifically [to] the validity of the agreement to arbitrate” and “challenges [to] the contract as a whole, either on a ground that directly affects the entire agreement {e.g., the agreement was fraudulently induced), or on the ground that the illegality of one of the contract’s provisions renders the whole contract invalid” (Buckeye Check Cashing, Inc. v Cardegna, 546 US 440, 444 [2006]). “[A]ttacks on the validity…
cited Cited as authority (rule) Lashiya D. Ellis v. JF Enterprises, LLC d/b/a Jeremy Franklin's Suzuki of Kansas City, Condor Capital Corp.
Mo. · 2016 · confidence medium
Nitro-Lift Techs., L.L.C. v. Howard, 133 S. Ct. 500, 503 (2012) (emphasis added).
discussed Cited as authority (rule) TALLMAN VS. DIST. CT. (CPS SECURITY (USA), INC.) (2×)
Nev. · 2015 · confidence medium
VI, cl. 2, and by the opinions of [the Supreme] Court interpreting that law." Nitro-Lift Techs., LLC v. Howard, 568 U.S. ,133 S. Ct. 500, 503 (2012).
cited Cited as authority (rule) MIKA VS. DIST. CT. (CPS SECURITY (USA), INC.)
Nev. · 2015 · confidence medium
VI, cl. 2, and by the opinions of [the Supreme] Court interpreting that law." Nitro-Lift Techs., LLC v. Howard, 568 U.S. , 133 S. Ct. 500, 503 (2012).
discussed Cited as authority (rule) MIKA VS. DIST. CT. (CPS SECURITY (USA), INC.) (2×)
Nev. · 2015 · confidence medium
VI, cl. 2, and by the opinions of [the Supreme] Court interpreting that law." Nitro-Lift Techs., LLC v. Howard, 568 U.S. , 133 S. Ct. 500, 503 (2012).
cited Cited as authority (rule) TALLMAN VS. DIST. CT. (CPS SECURITY (USA), INC.)
Nev. · 2015 · confidence medium
VI, cl. 2, and by the opinions of [the Supreme] Court interpreting that law." Nitro-Lift Techs., LLC v. Howard, 568 U.S. , 133 S. Ct. 500, 503 (2012).
discussed Cited as authority (rule) TUCKER v. THE COCHRAN FIRM-CRIMINAL DEFENSE BIRMINGHAM L.L.C. (2×)
Okla. · 2014 · confidence medium
Under the purview of this separability doctrine, a forum selection clause is deemed to be separate from, and independent of, the contract containing it.") 41 Greater Oklahoma City Amusements, Inc. v. Moyer , 1970 OK 213, 477 P.2d 73, 75 (quoting a legal encyclopedia). 42 Greater Oklahoma City Amusements, Inc. v. Moyer , 1970 OK 213, 477 P.2d at 75-76. 43 In Preston v. Ferrer , 552 U.S. 346, 349, 128 S.Ct. 978, 169 L.Ed.2d 917 (2008), the Court stated that "when parties agree to arbitrate all disputes arising under their contract, questions concerning the validity of the entire contract are to …
discussed Cited as authority (rule) LegalZoom.com, Inc. v. McIllwain
Ark. · 2013 · confidence medium
In a per curium opinion, the Supreme Court vacated an Oklahoma Supreme Court opinion, stating that the Oklahoma high court had “ignored the basic tenet of the [FAA’s] substantive arbitration law . . . [that] attacks on the validity of the contract, as distinct from attacks on the arbitration clause itself, are to be resolved by the arbitrator in the first instance, not by a federal or state court.” Id. at 501, 503 (citations omitted).
discussed Cited as authority (rule) Sequestration of Public Company Accounting Oversight Board Funds
OLC · 2013 · signal: cf. · confidence medium
Cf. Nitro-Lift Techs., LLC v. Howard, 133 S. Ct. 500, 504 (2012) (invoking the “ancient interpretive principle that the specific governs the general”).
examined Cited as authority (rule) McInnes v. LPL Financial, LLC (4×) also: Cited "see", Cited "see, e.g."
Mass. · 2013 · confidence medium
Nitro-Lift Techs., L.L.C. v. Howard, 133 S. Ct. 500, 503 (2012); Buckeye Check Cashing, Inc. v. Cardegna, supra at 445-446 .
discussed Cited as authority (rule) Schiffer v. Slomin's, Inc. (2×)
nydistctnassau · 2013 · confidence medium
In Nitro-Lift and Marmet the Supreme Court admonished state courts for not following the High Court’s interpretation of the Federal Arbitration Act regarding state prohibition of arbitration, e.g., “the Oklahoma Supreme Court must abide by the [Federal Arbitration Act], which is ‘the supreme Law of the Land’ “once [this] Court has spoken, it is the duty of other courts to respect that understanding of the governing rule of law” (Nitro-Lift Technologies, L.L.C. v Howard, 568 US —, —, 133 S Ct 500, 503 [2012]).
discussed Cited as authority (rule) Personal Communications Devices, LLC v. HTC America Inc.
N.Y. Sup. Ct. · 2013 · confidence medium
The Court set forth that, once the trial court determined that a contract binding the parties contained a valid arbitration clause, “it is a mainstay of the Act’s substantive law that attacks on the validity of the contract, as distinct from attacks on the validity of the arbitration clause itself, are to be resolved by the arbitrator in the first instance, not by a federal or state court.” (568 US at —, 133 S Ct at 503 [internal quotation marks omitted].) A careful review of the history of the parties’ commercial relationship, as well as the documents commencing from the July 2, 200…
discussed Cited as authority (rule) Kelker v. Geneva-Roth Ventures, Inc. (2×)
Mont. · 2013 · confidence medium
Nitro-Lift Techs., L.L.C. v. Howard,_U.S._, 133 S. Ct. 500, 503 (2012).
cited Cited as authority (rule) D.A. Osguthorpe Family Partnership v. ASC Utah, Inc.
10th Cir. · 2013 · confidence medium
Indeed, “[s]tate courts rather than federal courts are most frequently called upon to apply the Federal Arbitration Act.” Nitro-Lift Techs., L.L.C. v. Howard, 133 S. Ct. 500, 501 (2012) (per curiam).
discussed Cited "see" Shifrin v. Strata Equity Global CA4/1
Cal. Ct. App. · 2026 · signal: see · confidence high
(Richey v. AutoNation, Inc. (2015) 60 Cal.4th 909, 916 ; Ramirez v. Charter Communications, Inc. (2024) 16 Cal.5th 478 , 492; see Nitro-Lift Technologies, L.L.C. v. Howard (2012) 568 U.S. 17, 20 [FAA “ ‘declare[s] a national policy favoring arbitration’ ”]; Scherk v. Alberto-Culver Co. (1974) 417 U.S. 506, 510-511 [FAA was “designed to allow parties to avoid ‘the costliness and delays of litigation,’ and to place arbitration agreements ‘upon the same footing as other contracts’ ”]; Cronus Investments, Inc. v. Concierge Services (2005) 35 Cal.4th 376, 384 (Cronus) [section 2…
discussed Cited "see" Diane Johnston, individually and on behalf of all others similarly situated v. VGW Holdings, LTD., et al.
M.D. Ala. · 2026 · signal: see · confidence high
See Nitro-Lift Techs., LLC v. Howard, 568 U.S. 17 , 20–21 (2012) (per curiam) (“[I]t is a mainstay of the [FAA’s] substantive law that attacks on the validity of [a] contract, as distinct from attacks on the validity of the arbitration clause itself, are to be resolved ‘by the arbitrator in the first instance, not by a federal or state court.’” (quoting Preston v. Ferrer, 552 U.S. 346, 349 (2008))); Buckeye Check Cashing, Inc., 546 U.S. at 445–46 (“[U]nless the challenge is to the arbitration clause itself, the issue of the contract’s validity is considered by the arbitrator …
Retrieving the full opinion text from the archive…
NITRO-LIFT TECHNOLOGIES, L. L. C.
v.
HOWARD Et Al.
11-1377.
Supreme Court of the United States.
Nov 26, 2012.
133 S. Ct. 500
Per Curiam.
Cited by 211 opinions  |  Published
2 passages pin-cited by 2 cases
Pinpoint authority: bottom 76%
Citer courts: D. New Jersey (2) · E.D. Virginia (1)
Per Curiam.

State courts rather than federal courts are most frequently called upon to apply the Federal Arbitration Act (FAA or Act), 9 U. S. C. § 1 et seq., including the Act’s national policy favoring arbitration. It is a matter of great importance, therefore, that state supreme courts adhere to a[*18] correct interpretation of the legislation. Here, the Oklahoma Supreme Court failed to do so. By declaring the non-competition agreements in two employment contracts null and void, rather than leaving that determination to the arbitrator in the first instance, the state court ignored a basic tenet of the Act’s substantive arbitration law. The decision must be vacated.

* * *

This dispute arises from a contract between petitioner Nitro-Lift Technologies, L. L. C., and two of its former employees. Nitro-Lift contracts with operators of oil and gas wells to provide services that enhance production. Respondents Eddie Lee Howard and Shane D. Schneider entered a confidentiality and noncompetition agreement with Nitro-Lift that contained the following arbitration clause:

“‘Any dispute, difference or unresolved question between Nitro-Lift and the Employee (collectively the “Disputing Parties”) shall be settled by arbitration by a single arbitrator mutually agreeable to the Disputing Parties in an arbitration proceeding conducted in Houston, Texas in accordance with the rules existing at the date hereof of the American Arbitration Association.’” Pet. for Cert. 5.

After working for Nitro-Lift on wells in Oklahoma, Texas, and Arkansas, respondents quit and began working for one of Nitro-Lift’s competitors. Claiming that respondents had breached their noncompetition agreements, Nitro-Lift served them with a demand for arbitration. Respondents then filed suit in the District Court of Johnston County, Oklahoma, asking the court to declare the noncompetition agreements null and void and to enjoin their enforcement. The court dismissed the complaint, finding that the contracts contained valid arbitration clauses under which an arbitrator, and not the court, must settle the parties’ disagreement.

[*19] The Oklahoma Supreme Court retained respondents’ appeal and ordered the parties to show cause why the matter should not be resolved by application of Okla. Stat., Tit. 15, §219A (West 2011), which limits the enforceability of non-competition agreements. Nitro-Lift argued that any dispute as to the contracts’ enforceability was a question for the arbitrator. It relied for support— as it had done before the trial court—upon several of this Court’s cases interpreting the FAA, and noted that under Buckeye Check Cashing, Inc. v. Cardegna, 546 U. S. 440, 446 (2006), “this arbitration law applies in both state and federal courts.” Record in No. 109,003 (Okla.), p. 273.

The Oklahoma Supreme Court was not persuaded. It held that despite the “[U. SJ Supreme Court cases on which the employers rely,” the “existence of an arbitration agreement in an employment contract does not prohibit judicial review of the underlying agreement.” 2011 OK 98, ¶15, n. 20, ¶ 16, 273 P. 3d 20, 26, n. 20, 27. For that proposition, the court relied on the “exhaustive overview of the United States Supreme Court decisions construing the Federal Arbitration Act” in Bruner v. Timberlane Manor Ltd. Partnership, 2006 OK 90, 155 P. 3d 16, which found Supreme Court jurisprudence “not to inhibit our review of the underlying contract’s validity.” 273 P. 3d, at 26. Finding the arbitration clauses no obstacle to its review, the court held that the noncompetition agreements were “void and unenforceable as against Oklahoma’s public policy,” expressed in Okla. Stat., Tit. 15, § 219A. 273 P. 3d, at 27.

The Oklahoma Supreme Court declared that its decision rests on adequate and independent state grounds. Id., at 23-24, n. 5. If that were so, we would have no jurisdiction over this case. See Michigan v. Long, 463 U. S. 1032, 1037-1044 (1983). It is not so, however, because the court’s reliance on Oklahoma law was not “independent”—it necessarily depended upon a rejection of the federal claim, which was both “‘properly presented to’” and ‘“addressed by’” the[*20] state court. Howell v. Mississippi, 543 U. S. 440, 443 (2005) (per curiam) (quoting Adams v. Robertson, 520 U. S. 83, 86 (1997) (per curiam)). Nitro-Lift claimed that the arbitrator should decide the contract’s validity, and raised a federal-law basis for that claim by relying on Supreme Court cases construing the FA A. “‘[A] litigant wishing to raise a federal issue can easily indicate the federal law basis for his claim in a state-court petition or brief ... by citing in conjunction with the claim the federal source of law on which he relies or a case deciding such a claim on federal grounds Howell, supra, at 444 (quoting Baldwin v. Reese, 541 U. S. 27, 32 (2004); emphasis added). The Oklahoma Supreme Court acknowledged the cases on which Nitro-Lift relied, as well as their relevant holdings, but chose to discount these controlling decisions. Its conclusion that, despite this Court’s jurisprudence, the underlying contract’s validity is purely a matter of state law for state-court determination is all the more reason for this Court to assert jurisdiction.

The Oklahoma Supreme Court’s decision disregards this Court’s precedents on the FAA. That Act, which “declare[s] a national policy favoring arbitration,” Southland Corp. v. Keating, 465 U. S. 1, 10 (1984), provides that a “written provision in ... a contract evidencing a transaction involving commerce to settle by arbitration a controversy thereafter arising out of such contract or transaction ... shall be valid, irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of any contract.” 9 U. S. C. § 2. It is well settled that “the substantive law the Act created [is] applicable in state and federal courts.” Southland Corp., supra, at 12; see also Buckeye, supra, at 446. And when parties commit to arbitrate contractual disputes, it is a mainstay of the Act’s substantive law that attacks on the validity of the contract, as distinct from attacks on the validity of the arbitration clause itself, are to be resolved “by the arbitrator in the first instance, not by a fed[*21] eral or state court.” Preston v. Ferrer, 552 U. S. 346, 349 (2008); see also Prima Paint Corp. v. Flood & Conklin Mfg. Co., 388 U. S. 396 (1967). For these purposes, an “arbitration provision is severable from the remainder of the contract,” Buckeye, supra, at 445, and its validity is subject to initial court determination; but the validity of the remainder of the contract (if the arbitration provision is valid) is for the arbitrator to decide.

This principle requires that the decision below be vacated. The trial court found that the contract contained a valid arbitration clause, and the Oklahoma Supreme Court did not hold otherwise. It nonetheless assumed the arbitrator’s role by declaring the noncompetition agreements null and void. The state court insisted that its “[own] jurisprudence controls this issue” and permits review of a “contract submitted to arbitration where one party assertfe] that the underlying agreement [is] void and unenforceable.” 273 P. 3d, at 26. But the Oklahoma Supreme Court must abide by the FAA, which is “the supreme Law of the Land,” U. S. Const., Art. VI, el. 2, and by the opinions of this Court interpreting that law. “It is this Court’s responsibility to say what a statute means, and once the Court has spoken, it is the duty of other courts to respect that understanding of the governing rule of law.” Rivers v. Roadway Express, Inc., 511 U. S. 298, 312 (1994). Our cases hold that the FAA forecloses precisely this type of “judicial hostility towards arbitration.” AT&T Mobility LLC v. Concepcion, 563 U. S. 333, 342 (2011).

The state court reasoned that Oklahoma’s statute “addressing the validity of covenants not to compete, must govern over the more general statute favoring arbitration.” 273 P. 3d, at 26, n. 21. But the ancient interpretive principle that the specific governs the general (generalia specialibus non derogant) applies only to conflict between laws of equivalent dignity. Where a specific statute, for example, conflicts with a general constitutional provision, the latter governs. And the same is true where a specific state stat[*22] ute conflicts with a general federal statute. There is no general-specific exception to the Supremacy Clause, U. S. Const., Art. VI, cl. 2. “ ‘[WJhen state law prohibits outright the arbitration of a particular type of claim, the analysis is straightforward: The conflicting rule is displaced by the FA A.’” Marmet Health Care Center, Inc. v. Brown, 565 U. S. 530, 533 (2012) (per curiam) (quoting AT&T Mobility LLC, supra, at 341). Hence, it is for the arbitrator to decide in the first instance whether the covenants not to compete are valid as a matter of applicable state law. See Buckeye, 546 U. S., at 445-446.

For the foregoing reasons, the petition for certiorari is granted. The judgment of the Supreme Court of Oklahoma is vacated, and the case is remanded for proceedings not inconsistent with this opinion.

It is so ordered.