Subway Restaurants, Inc. v. Matthew Warciak

Before this Court decided Arthur Andersen LLP v. Carlisle, 556 U.S. 624 (2009), federal courts had developed a federal version of the equitable estoppel doctrine that permits a non-signatory to enforce an arbitration agreement in certain circumstances. In its decision below, the Seventh Circuit held that the Arthur Andersen Court eliminated the federal equitable estoppel doctrine. It reached that conclusion even though the Arthur Andersen Court never addressed the federal doctrine of equitable estoppel, let alone abrogated it. Meanwhile, other circuits continue to apply the federal doctrine. The question presented is: Whether this Court’s decision in Arthur Andersen LLP v. Carlisle, 556 U.S. 624 (2009), eliminated the federal equitable estoppel doctrine. (i)