Smith v. Spizzirri: A Requested FAA Stay Is Mandatory

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Delivery drivers brought wage claims and the defendants moved to compel arbitration. Everyone agreed the claims were arbitrable; the dispute was whether the district court could dismiss instead of stay.

Facts and posture

The drivers alleged misclassification and violations of federal and state employment laws. After removal, the defendants sought arbitration and dismissal, while the workers requested a stay.

Issue and arguments

The defendants relied on circuit practice allowing dismissal when all claims were arbitrable. The workers relied on section 3’s command that the court “shall” stay upon application.

Reasoning and holding

The Court held the statutory text foreclosed dismissal when a stay was requested. A stay preserves the court’s supervisory role and limits immediate appellate consequences Congress did not authorize.

Disposition

The judgment was reversed and remanded with instructions consistent with the mandatory stay rule.

Limits, subsequent use, and practical implications

The opinion concerns federal-court procedure under FAA section 3. It does not decide whether an arbitration agreement is enforceable, whether a worker falls within the FAA transportation-worker exemption, or the merits of employment claims.