PAUL PERRUZZI; JEREMIAH SULLIVAN v. CAMPBELL SOUP COMPANY; SNYDER'S-LANCE, INC
The First Circuit vacated and remanded a district court order that administratively closed a case without addressing the plaintiffs' claim that the Federal Arbitration Act exempts transportation workers from mandatory arbitration. The appellate court held that the lower court must explicitly rule on the Section 1 exemption argument before determining whether to stay or close the proceedings.