St. John's Law Review

The Arbitrators' Duty to Respect the Parties' Choice of Law in Commercial Arbitration

By: Cindy G. Buys

Arbitration is all about choice.  The parties choose whether to arbitrate their disputes, whom the decision-makers will be, where the arbitration will take place, and what procedures will be applied. One of arbitration’s defining characteristics is party autonomy, which is sometimes used specifically to refer to the parties’ ability to choose the law that will govern their dispute. As noted by one scholar, “The right of parties to themselves identify the law to apply and the obligation on arbitrators to respect that choice is the one overwhelming and truly international conflict of laws rule which has developed in international commercial arbitration.” By contrast, in domestic commercial arbitration, outdated parochial rules sometimes still apply to invalidate the parties’ choice of applicable law.  In such cases, arbitrators and reviewing courts will not honor the parties’ choice of law unless the law chosen bears a reasonable or substantial relationship to the parties or the underlying transaction.  The purpose of this article is to demonstrate that there is no valid reason to disregard the mutually agreed-upon choice of law made by the parties to an arbitration agreement arising out of a commercial transaction, provided that there are no extenuating circumstances. 

This article contends that domestic commercial arbitration is more similar to international commercial arbitration than to domestic litigation, such that the conflict of laws rules that apply in international commercial arbitration should apply to domestic commercial arbitration as well.  The corollary to this theory is that there are significant differences between commercial arbitration and commercial litigation, such that different conflict of laws rules ought to apply.  Thus, arbitrators and reviewing courts should respect the choice of law made by the parties to a domestic commercial arbitration agreement regardless of whether there is any connection between the underlying transaction and the law chosen, just as is done in international commercial arbitration.