scope of the arbitration clause (Florida) · Go Syfert
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scope of the arbitration clause in Florida

16 Florida opinions name it 2 courts 1993–2024 5 in the last five years

The cases below were cited by Florida courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
Mediterranean Enterprises, Inc. v. Ssangyong Corporationgreen
ca9 · 1983 · cited in 2 Florida opinions naming this issue, 1999–2012
2 sentences

2012See Mediterranean Enters., Inc. v. Ssangyong Corp., 708 F.2d 1458 , 1464 (9th Cir.1983); In re Kinoshita & Co., 287 F.2d 951, 953 (2d Cir.1961).

1999See Mediterranean Enters., Inc. v. Ssangyong *637 Corp., 708 F.2d 1458 , 1464 (9th Cir.1983); In re Kinoshita & Co., 287 F.2d 951, 953 (2d Cir.1961).

22
cluster 253402green
ca2 · 1961 · cited in 2 Florida opinions naming this issue, 1999–2012
2 sentences

2012See Mediterranean Enters., Inc. v. Ssangyong Corp., 708 F.2d 1458 , 1464 (9th Cir.1983); In re Kinoshita & Co., 287 F.2d 951, 953 (2d Cir.1961).

1999See Mediterranean Enters., Inc. v. Ssangyong *637 Corp., 708 F.2d 1458 , 1464 (9th Cir.1983); In re Kinoshita & Co., 287 F.2d 951, 953 (2d Cir.1961).

22
Seifert v. US Home Corp.green
fla · 1999 · cited in 4 Florida opinions naming this issue, 2009–2024
2 sentences

2011See, e.g., Seifert v. U.S. Home Corp. 750 So.2d 633, 637 (Fla.1999) (recognizing that adding the phrase "relating to” to the phrase “arising out of” has the effect of broadening the scope of the arbitration clause).

2011See, e.g., Seifert v. U.S. Home Corp. 750 So.2d 633, 637 (Fla. 1999) (recognizing that adding the phrase "relating to" to the phrase "arising out of" has the effect of broadening the scope of the arbitration clause). [7] Although the concurring opinion states that the trial court erred in denying arbitration of the Second Amended Complaint, that opinion then goes on to address itself instead to the trial court's April 21, 2010, Order on Motion to Dismiss Amended Complaint, in which the trial court (1) denied the defendants' motion to dismiss, (2) granted Dobal leave to file her Second Amended

14
Estate of Shambow v. Shambowgreen
fla · 1943 · cited in 1 Florida opinions naming this issue, 2024–2024
1 sentence

2024In re Shambow’s Est., 15 So. 2d 837, 837 (Fla. 1943). 6 “apply[] general state-law principles of contract interpretation,” here, and put the arbitration provision on “equal footing” with any other contract, we apparently still must give “due regard . . . to the federal policy favoring arbitration,” resolving “ambiguities as to the scope of the arbitration clause itself . . . in favor of arbitration.” Volt Info.

11
Federal Vending, Inc. v. Steak & Ale of Florida, Inc.green
fladistctapp · 1997 · cited in 1 Florida opinions naming this issue, 2023–2023
1 sentence

2023Vending, Inc. v. Steak & Ale of Fla., Inc., 687 So. 2d 1366, 1368 (Fla. 4th DCA 1997).

11
Armas v. Prudential Securities, Inc.green
fladistctapp · 2003 · cited in 1 Florida opinions naming this issue, 2021–2021
1 sentence

2021The signatories to the Agent Agreements expressly agreed that “any dispute arising out of or related in any way to the 7 solicitation, negotiation, inception or performance of this Agreement . . . shall be exclusively resolved . . . [by] arbitration.” This Court has recognized such language as permitting non-signatories to enforce arbitration agreements. “[A]rbitration provisions containing the language, ‘arising out of or related to,’ in certain instances can be construed to include non-signatories.” Armas v. Prudential Sec., Inc., 842 So. 2d 210, 211 (Fla. 3d DCA 2003).

11
Sherer v. Green Tree Servicing LLCgreen
ca5 · 2008 · cited in 1 Florida opinions naming this issue, 2019–2019
2 sentences

2019Sherer v. Green Tree Servicing LLC, 548 F.3d 379, 381 (5th Cir. 2008), is inapposite because the parties in Sherer did not challenge "that the claims would otherwise be within the scope of the arbitration clause '[h]ad the defendant signed the contract.' " (Alteration in original.) Instead, the sole issue in Sherer was "whether Sherer ha[d] agreed to arbitration with a nonsignatory, such as Green Tree." Id.

2019Sherer v. Green Tree Servicing LLC, 548 F.3d 379, 381 (5th Cir. 2008), is inapposite because the parties in Sherer did not challenge "that the claims would otherwise be within the scope of the arbitration clause '[h]ad the defendant signed the contract.' " (Alteration in original.) Instead, the sole issue in Sherer was "whether Sherer ha[d] agreed to arbitration with a nonsignatory, such as Green Tree." Id.

11
Kroma Makeup EU, LLC v. Boldface Licensing + Branding, Inc.green
ca11 · 2017 · cited in 1 Florida opinions naming this issue, 2018–2018
2 sentences

2018Therefore, even when a non- signatory can rely on equitable estoppel “to access [the arbitration] clause,” the non-signatory can compel arbitration only if the dispute at issue “falls within the scope of the arbitration clause.” Kroma Makeup EU, LLC v. Boldface Licensing + Branding, Inc., 845 F.3d 1351, 1355 (11th Cir. 2017) (applying Florida law).

2018Therefore, even when a non-signatory can rely on equitable estoppel “to access [the arbitration] clause,” the non- signatory can compel arbitration only if the dispute at issue “falls within the scope of the arbitration clause.” Kroma Makeup EU, LLC v. Boldface Licensing + Branding, Inc., 845 F.3d 1351, 1355 (11th Cir. 2017) (emphasis added) (applying Florida law).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
Volt Info. Sciences, Inc. v. Bd. of Trustees of Leland Stanford Jr. U. green
scotus · 1989
2 sentences

2024Scis., Inc. v. Bd. of Trs. of Leland Stanford Junior Univ., 489 U.S. 468 , 475–76 (1989) (internal citation omitted); see Moses H.

1996Sciences, Inc. v. Stanford Univ., 489 U.S. 468, 475-76 , 109 S.Ct. 1248, 1254 , 103 L.Ed.2d 488 (1989); Moses H.

21996–2024
Beck Auto Sales, Inc. v. Asbury Jax Ford, LLC, and Lisa Marasco green
fladistctapp · 2018
2 sentences

2024P'ship, LLP v. Rays Baseball Club, LLC, 371 So. 3d 988 , 991 (Fla. 2d DCA 2023) (holding that the scope of the arbitration clause is a matter of contractual interpretation requiring the examination of the plain language used by the parties in their contract (first quoting Beck Auto Sales, Inc., 249 So. 3d at 768 ; and then quoting Bailey, 309 So. 3d at 701)).

2024P'ship, LLP v. Rays Baseball Club, LLC, 371 So. 3d 988 , 991 (Fla. 2d DCA 2023) (holding that the scope of the arbitration clause is a matter of contractual interpretation requiring the examination of the plain language used by the parties in their contract (first quoting Beck Auto Sales, Inc., 249 So. 3d at 768 ; and then quoting Bailey, 309 So. 3d at 701)).

22024–2024
American Recovery Corporation v. Computerized Thermal Imaging, Incorporated green
ca4 · 1996
1 sentence

2011Recovery Corp. v. Computerized Thermal Imaging, Inc., 96 F.3d 88 , 93 (4th Cir.1996) (quoting J.J.

12011–2011
MEDIDENT CONSTRUCTION v. Chappell green
fladistctapp · 1994
1 sentence

2005Because the buyers do not attack the validity of the arbitration clause, but instead seek to invalidate the entire agreement, “[t]he relief [the buyers seek] falls within the scope of the arbitration clause and should be submitted to arbitration.” Id.

12005–2005
Diez-Sierra v. Aguera neutral
fladistctapp · 2000
1 sentence

2005We find the decision in Diez-Sierra v. Aguera, 762 So.2d 557 (Fla. 3d DCA 2000), distinguishable on at least two grounds.

12005–2005
M. Sylvain Ledee v. Ceramiche Ragno green
ca1 · 1982
1 sentence

2002"The clause must be interpreted to encompass only those situations—such as fraud, mistake, duress and waiver—that can be applied neutrally on an international scale." Id. [10] Cases dealing with this last prong usually rely on the parties' citizenship; however, we do not have the benefit of that information and, therefore, we analyze the fourth requirement in terms of the insurance contract's reasonable relation with one or more foreign states. [11] The parties do not question the scope of the arbitration clause. [12] There is no evidence to suggest that Setton agreed to the policy terms as a

12002–2002
Ronbeck Const. Co., Inc. v. Savanna Club Corp. green
fladistctapp · 1992
1 sentence

1993Old Dominion Insurance Co. v. Dependable Reinsurance Co., 472 So.2d 1365 (Fla. 1st DCA 1985); see generally, Florida Construction Law and Practice § 13.8 (2d ed.); Ronbeck Construction Co., Inc. v. Savanna Club Corporation, 592 So.2d 344 (Fla. 4th DCA 1992).

11993–1993
Old Dominion Ins. v. DEPENDABLE REINS. green
fladistctapp · 1985
1 sentence

1993Old Dominion Insurance Co. v. Dependable Reinsurance Co., 472 So.2d 1365 (Fla. 1st DCA 1985); see generally, Florida Construction Law and Practice § 13.8 (2d ed.); Ronbeck Construction Co., Inc. v. Savanna Club Corporation, 592 So.2d 344 (Fla. 4th DCA 1992).

11993–1993

Statutes the citing opinions construe

USC § 9u.s.c.2 (5) USC § 9u.s.c.1 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 83 (1997–2025) IL 74 (1976–2026) OH 73 (1996–2025) CA 52 (1979–2025) NY 36 (1956–2024) MN 25 (1975–2004) NJ 23 (1990–2022) PA 23 (1925–2026) SC 20 (1993–2021) MD 19 (1983–2026) AL 18 (1995–2013) FL 16 (1993–2024) CO 13 (1977–2015) MS 12 (2000–2017) MO 7 (2008–2016) MI 7 (1990–2026) CT 6 (1991–2009) GA 6 (2003–2025) IN 6 (2004–2012) LA 5 (2003–2016) NM 5 (2006–2024) TN 5 (2001–2015) NC 5 (1985–2011) VA 3 (1996–2011) UT 3 (2013–2023) WI 3 (2015–2015) AZ 3 (2012–2014) WA 3 (1998–2021) OR 3 (2005–2007) MT 2 (1986–1993) DE 2 (2008–2017) ME 2 (1993–2020) AK 2 (2005–2013) DC 2 (2013–2014) HI 2 (2018–2020) MA 2 (1992–2009) ID 2 (2003–2010)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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