HeinOnline is a subscription-based resource containing thousands of academic and legal journals from inception; complete coverage of government documents such as U.S. Statutes at Large, U.S. Code, Federal Register, Code of Federal Regulations, U.S. Reports, and much more. Documents are image-based, fully searchable PDFs with the authority of print combined with the accessibility of a user-friendly and powerful database. For more information, request a quote or trial for your organization below.
![handle is hein.crs/govengs0001 and id is 1 raw text is:
a Congressional ______
Rsesearch Service
Coinbase, Inc. v. Bielski: Federal Trial Courts
Must Halt Proceedings During Arbitration
Appeals
October 26, 2023
In Coinbase, Inc. v. Bielski, the Supreme Court ruled in a 5-to-4 decision that federal district courts must
stay pre-trial and trial proceedings when a party appeals an order denying a motion to compel arbitration
under Section 16 of the Federal Arbitration Act (FAA) (9 U.S.C. § 16). The Court's decision resolved a
circuit split in the federal appeals courts. While most federal circuit courts of appeals to address the issue
had already followed this automatic-stay rule, the Second, Fifth, and Ninth Circuits did not. Those
Circuits had instead held that district courts have discretion to proceed to trial while an appeal from a
denial of a motion to compel arbitration is pending.
The automatic-stay rule adopted in Coinbase has significant implications for parties who litigate federal
lawsuits involving arbitration agreements. In the majority's view, for example, requiring district courts to
halt proceedings while an appellate court decides whether the case belongs in arbitration prevents
defendants from irretrievably losing many of the perceived benefits of arbitrating their dispute-such as
efficiency, lower costs, and less intrusive discovery-and avoids nullif[ying] the right to an immediate
appeal that Congress provided in 9 U.S.C. § 16(a). In the dissent's view, in contrast, the Court's decision
could force district courts to halt proceedings during arbitrability appeals for potentially months or years
and leave plaintiffs to suffer harm, lose evidence, and bleed dry their patience and funding in the
meantime. This Legal Sidebar provides background on relevant aspects of the FAA, analyzes the
Supreme Court's Coinbase decision, and discusses legal considerations for Congress.
Background
Arbitration agreements are common in consumer, employment, and other commercial contexts. These
agreements generally waive the parties' right to litigate future disputes in court and instead require them
to resolve disputes in binding arbitration before a neutral third party. Arbitration agreements may also
limit other procedural rights, such as by precluding class action proceedings and requiring parties to
arbitrate disputes on an individual basis.
Congressional Research Service
https://crsreports.congress.gov
LSB11062
CRS Legal Sidebar
Prepared for Members and
Committees of Congress](ViewImageLocal?handle=hein.crs/govengs0001&div=1&collection=&method=preview&ext=.png&size=3)