Harry Baker Smith Architects II, PLLC v. Sea Breeze I, LLC, 83 So. 3d 395

Sea Breeze contracted with HBSA and Roy Anderson for design and construction of a condo project; both contracts contained arbitration provisions.
After alleged defects, Sea Breeze sought arbitration against HBSA and Roy Anderson; parties consented to AAA special arbitrator for consolidation consideration.
The AAA appointed a special arbitrator to decide whether consolidation/joinder was appropriate under construction industry arbitration rules.
The arbitrator found consolidation proper, noting HBSA could join and that Roy Anderson’s involvement was required for complete relief.
HBSA sought injunctive relief and reversal in chancery court; the court denied relief, granted the motion to compel arbitration, and declined to review the arbitrator’s consolidation decision.
HBSA appeals arguing lack of jurisdiction to overturn consolidation, error in compelling consolidation, and denial of injunctive relief; court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether chancery court could review the arbitrator’s consolidation decision.	HBSA argues court may review arbitrability and consolidation.	Sea Breeze and Roy Anderson contend only gateway matters are reviewable.	Chancery court lacked authority to overturn consolidation.
Whether consolidation was proper under the arbitration agreements.	HBSA disputes consolidation, seeking reversal.	Sea Breeze and Roy Anderson support consolidation as proper.	Arbitration consolidation affirmed; arbitration proceeded jointly.

First Options of Chi. v. Kaplan, 514 U.S. 938 (1995) (gateway questions limit court review; arbitratability subject to narrow review)
Green Tree Fin. Corp. v. Bazzle, 539 U.S. 444 (2003) (limits on courts reviewing arbitration consolidation; gateway matters only)
Derr Plantation, Inc. v. Swarek, 14 So.3d 711 (Miss. 2009) (de novo review of questions of law, including jurisdiction)