On April 2, 2020, the Second Circuit held that an arbitration
award could not be enforced against a parent company that was not a
signatory to a contract's arbitration agreement, even though
the parent company was listed in the contract as a guarantor and
was involved in the purchase of goods pursuant to the contract.
In so doing, the Court confirmed its commitment to a literal,
textualist approach to contractual interpretation notwithstanding
the commercial realities indicating that the parent company was
involved in the parties' relationship and played a key role in
the dispute from which the arbitration arose.
Judicial Authority to Determine Obligations of a Non-Signatory
to an Arbitration Agreement
