Blissett v. Pate’s Auto Group, LLC, et al.

Blissett v. Pate’s Auto Group, LLC, No. 3:25-cv-00310-JDM-JMV (N.D. Miss. Mar. 26, 2026) · United States District Court for the Northern District of Mississippi · March 26, 2026 · No. 3:25-cv-00310-JDM-JMV

Summary

The United States District Court for the Northern District of Mississippi granted the defendants’ motion to compel arbitration in a dispute arising from the repossession of a truck purchased by the plaintiff’s minor son. The court held that the arbitration agreement contained a valid delegation clause covering disputes concerning arbitrability, notice, and waiver, and therefore referred those issues to the arbitrator. The court stayed the case and ordered periodic status updates regarding arbitration.

Holdings

  1. A valid and enforceable agreement to arbitrate existed between Blissett and the Pates.
  2. The arbitration agreement’s delegation clause validly assigned questions concerning the validity, scope, and interpretation of the arbitration provision to the arbitrator.
  3. The arbitrator, not the court, must decide whether the Pates received notice, failed to comply with AAA rules, defaulted, or waived their right to arbitrate.

Questions Presented

  1. Whether a valid and enforceable agreement to arbitrate existed between Blissett and the Pates.
  2. Whether the arbitration agreement validly delegated arbitrability to the arbitrator.
  3. Whether disputes concerning notice of arbitration, failure to pay AAA fees, waiver, and default were procedural arbitrability issues for the arbitrator rather than the court.

Disposition

other

Cases Cited (6)

  • Kubala v. Supreme Production Services, Inc., 830 F.3d 199, 201-02 (5th Cir. 2016)(followed)
  • Matter of Willis, 944 F.3d 577, 579 (5th Cir. 2019)(followed)
  • Rent-A-Center, West, Inc. v. Jackson, 561 U.S. 63, 68-69 (2010)(followed)
  • Town of Amherst v. Custom Lighting Services, LLC, No. 07-CV-261S, 2007 WL 4264608, at *11 (W.D.N.Y. Nov. 30, 2007)(followed by analogy)
  • Howsam v. Dean Witter Reynolds, Inc., 537 U.S. 79, 84-85 (2002)(followed)
  • John Wiley & Sons, Inc. v. Livingston, 376 U.S. 543, 557 (1964)(followed)

Cited In (0)

No citing cases on record yet.

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