Coinbase v. Suski
602 U.S. 143
SCOTUS2024Background
- Coinbase, Inc. operates a cryptocurrency exchange platform and requires users to agree to a User Agreement with an arbitration clause containing a delegation provision (arbitrator decides arbitrability).
- Later, Coinbase offered a sweepstakes, which respondents (users) entered, agreeing to the Official Rules with a forum selection clause (California courts have exclusive jurisdiction).
- After the sweepstakes, users filed a class action in federal court alleging California law violations concerning the sweepstakes.
- Coinbase moved to compel arbitration, invoking the delegation clause in the User Agreement.
- The district court denied arbitration, holding the forum selection clause in the Official Rules controlled; the Ninth Circuit affirmed.
- The Supreme Court granted certiorari to decide whether a court or arbitrator determines which contract governs arbitrability when two contracts conflict on dispute resolution.
Issues
| Issue | Suski (Plaintiff) Argument | Coinbase (Defendant) Argument | Held |
|---|---|---|---|
| Who decides arbitrability when two contracts conflict (one with delegation clause, one with forum selection clause)? | The sweepstakes' Official Rules (forum selection clause) control, sending disputes to California courts, not arbitration. | The User Agreement’s delegation clause governs all subsequent disputes, requiring an arbitrator to decide arbitrability. | A court must decide which contract controls – i.e., whether parties agreed to send arbitrability disputes to arbitration or court. |
Key Cases Cited
- United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (establishes the limited role of a syllabus in Supreme Court opinions)
- Rent-A-Center, West, Inc. v. Jackson, 561 U.S. 63 (arbitration is a matter of contract; explains the severability doctrine)
- First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938 (describes varying levels of arbitration agreements and who decides arbitrability questions)
- Buckeye Check Cashing, Inc. v. Cardegna, 546 U.S. 440 (arbitration clause is severable from the contract and validity challenges may trigger judicial review)
- AT&T Technologies, Inc. v. Communications Workers, 475 U.S. 643 (courts should not assume parties agreed to arbitrate arbitrability unless clear and unmistakable evidence exists)
- Prima Paint Corp. v. Flood & Conklin Mfg. Co., 388 U.S. 395 (articulates the principle of contract formation in arbitration disputes)