Stolt-Nielsen S.A. v. AnimalFeeds International Corp

In Stolt-Nielsen S.A. v. AnimalFeeds International Corp. (2010) 559 U.S. 662, the relevant arbitration agreement was silent with respect to class arbitration. (Id. at pp. 667-668.) Nevertheless, a panel of arbitrators ruled that the arbitration agreement allowed for class arbitration. (Id. at p. 669.) The United States Supreme Court held that this exceeded the arbitrators' powers. (See Stolt-Nielsen S.A. v. AnimalFeeds International Corp., supra, 559 U.S. at pp. 671-672.) "An implicit agreement to authorize class-action arbitration . . . is not a term that the arbitrator may infer solely from the fact of the parties' agreement to arbitrate." (Id. at p. 685.) Rather, "a party may not be compelled under the FAA to submit to class arbitration unless there is a contractual basis for concluding that the party agreed to do so." (Id. at p. 684.)