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An arbitration agreement that includes "any claims under this agreement" is sufficiently broad to encompass all disputes. Further, an arbitration agreement contained within one contract is applicable to additional contracts if they are connected by language and temporal proximity and are part of an ongoing business transaction, a federal court in Washington held.
In Stuchiner v. Sedona Oil and Gas Corp., No. C06-5639-RJB, 2007 WL 215857 (W.D. Wash. Jan. 25, 2007), Stuchiner and Sedona entered into three contracts regarding oil and gas wells, two of which did not have an arbitration agreement. Stuchiner filed suit alleging complaints that related to all three contracts. Sedona filed a motion to dismiss on the ground that the dispute should be submitted to arbitration.
Stuchiner argued that the arbitration agreement was too narrow to include this dispute. The Court disagreed. The language "any claims under this agreement" was sufficient to broaden the scope of the agreement. The Court further disagreed with Stuchiner's argument that only the claims relating to the contract which contained the arbitration agreement were subject to arbitration. The contracts were not distinct but were connected to each other by language and temporal proximity. Additionally, the contracts were part of an ongoing business transaction. See International Ambassador Programs v. Archexpo, 68 F.3d 337, 339-40 (9th Cir. 1993).
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