State of West Virginia ex rel. Williams WPC-1, LLC v. the Honorable Jeffrey Cramer, Judge of the Circuit Court of Marshall County, 21-0423

Respondent Coty Lantz worked for Williams and was terminated on January 6, 2021; he sued for retaliatory discharge on February 9, 2021.
Petitioners Williams WPC-1, LLC and Lee Dawson moved to dismiss and compel arbitration, relying on a company arbitration agreement effective January 1, 2020.
The arbitration agreement contained a delegation clause assigning questions about the agreement’s enforceability to an arbitrator.
Lantz opposed arbitration, denying any contract formation and arguing the arbitration agreement was unenforceable as a whole.
The circuit court denied the motion to compel, finding petitioners had not proven formation of an arbitration contract.
The Supreme Court granted a writ of prohibition, holding the circuit court erred by failing to enforce the delegation clause and directing arbitration of arbitrability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Who decides arbitrability?	Williams: the delegation clause gives the arbitrator power to decide enforceability.	Lantz: no arbitration contract was formed; entire agreement is unenforceable.	Court: delegation clause is severable and presumptively valid; arbitrator must decide arbitrability.
Is a writ of prohibition appropriate to correct the circuit court order?	Petitioners: no adequate appellate remedy, will suffer prejudice if forced to litigate issues delegated to arbitrator.	Respondent: circuit court correctly found no contract; prohibition unnecessary.	Court: writ granted — lower court clearly erred and petitioners lack an adequate remedy on appeal.

Schumacher Homes of Circleville, Inc. v. Spencer, 237 W. Va. 379, 787 S.E.2d 650 (W. Va. 2016) (defines delegation provision and severability doctrine)
Rent-A-Ctr., W., Inc. v. Jackson, 561 U.S. 63 (U.S. 2010) (delegation clauses can commit enforceability questions to arbitrators)
Prima Paint Corp. v. Flood & Conklin Mfg. Co., 388 U.S. 395 (U.S. 1967) (doctrine of separability/severability of arbitration clauses)
State ex rel. Richmond Am. Homes of W. Va., Inc. v. Sanders, 228 W. Va. 125, 717 S.E.2d 909 (W. Va. 2011) (under FAA, challenges to entire contract do not defeat arbitration clause validity)
Rent-A-Ctr., Inc. v. Ellis, 241 W. Va. 660, 827 S.E.2d 605 (W. Va. 2019) (party must specifically challenge delegation provision to keep court from enforcing it)
State ex rel. Hoover v. Berger, 199 W. Va. 12, 483 S.E.2d 12 (W. Va. 1996) (factors for issuing writ of prohibition)