Within weeks of its issuance, SCOTUS’s Sutter decision is already making an impact on other cases. Both the Eleventh Circuit and the D.C. Court of Appeals citeSutter repeatedly in recent decisions that refuse to vacate arbitration awards. Of course, new decisions are not the only ones that reverberate: Concepcion, a 2011 decision, was just applied by the Ninth Circuit to preempt Montana case law on contracts of adhesion.
Sutter
In Southern Commc’n Servs., Inc. v. Thomas, __ F.3d...