Summary
The United States District Court for the Western District of Tennessee grants Bank of America’s unopposed motion to compel arbitration in Kristopher Davis’s action against the Bank. The court denies the request to dismiss the case, explaining that under Smith v. Spizzirri, a federal court lacks discretion to dismiss when a party requests a stay pending arbitration.
Court
United States District Court for the Western District of Tennessee
Jurisdiction
United States District Court for the Western District of Tennessee
Decision date
February 10, 2026
Docket number
2:25-cv-03088-SHL-cgc
Disposition
other
Questions Presented
- Whether the court should compel arbitration when the plaintiff acknowledges that his claims are subject to the defendant's arbitration policy.
- Whether the court may dismiss the action instead of staying it after referring the claims to arbitration.
Holdings
- Because the parties did not dispute that Davis's claims were subject to the Bank's Arbitration Policy, the court compelled the parties to arbitrate the claims.
- When a federal court finds that a dispute is subject to arbitration and a party has requested a stay pending arbitration, the court does not have discretion to dismiss the action merely because all claims are arbitrable.
Court Document
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