I am always reluctant to do articles on arbitration, since one would think that not much new or interesting can be said regarding this area of the law. Yet, once upon a time I counted cases and I saw more decisions on arbitration, than any other subject. It is still a hot topic, and the courts have a lot to say about arbitrations, such as when arbitration is required, and when an arbitration clause is ineffective.

Sapp v. Industrial Action Servsices, 2023 U.S. App. LEXIS 18428, 2023 WL 4632784 (3d Cir. July 20, 2023) (Ambro, C.J.), from the U.S. Court of Appeals for the Third Circuit, is an interesting twist on the issue of when an arbitration is required.

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