In the case of Karim v. Finch Shipping Co., the court held that while arbitration provisions are valid and enforceable in any maritime transaction, the Federal Arbitration Act carves an exception for the validity and enforceability of arbitration provisions that do not apply to seaman employment contracts. However, in Franciscov. Stalt Achievement MT, the court held that the Convention on Recognition of Foreign Arbitral Awards trumps the Federal Arbitration Act’s exclusion of arbitration enforceability in the context of seaman employment contracts.
