Mitsubishi Motors Corp. v. Soler Chrysler-Plymouth
Citation and Court
473 U.S. 614 (1985), Supreme Court of the United States
Facts
Mitsubishi Motors (a Japanese company) entered a distribution agreement with Soler Chrysler-Plymouth (a Puerto Rican dealer) containing a Swiss arbitration clause. When Soler refused to accept car shipments, Mitsubishi filed for arbitration in Japan. Soler counterclaimed, alleging Sherman Act antitrust violations, and argued antitrust claims were not arbitrable.
Issue
Whether federal antitrust claims arising under the Sherman Act are arbitrable in the context of an international commercial arbitration agreement.
Holding
Antitrust claims are arbitrable under an international arbitration clause; the strong federal policy favoring arbitration, especially in the international commercial context, requires enforcement of the clause.
Rule / Doctrine
Statutory claims, including antitrust claims, may be arbitrated when the parties have agreed to arbitration in an international commercial context. The court noted the “judicial gloss” concept — U.S. courts may review the award to ensure antitrust policy was vindicated — but enforced arbitrability nonetheless.
Significance
Mitsubishi Motors is a landmark case extending the federal policy favoring arbitration to international commercial disputes involving U.S. statutory claims. It paved the way for arbitration of employment discrimination, securities, and other statutory claims in subsequent decisions, and remains a cornerstone of international arbitration law.