HD Hyundai Const. Equip. North America, Inc., etc. v. Southern Lift Trucks, LLC, [Ms. SC-2023-0853, Jan. 17, 2025] __ So. 3d __ (Ala. 2025). The Court (Cook, J.; Parker, C.J., and Shaw, Wise, Bryan, and Mitchell, JJ., concur; Sellers, Mendheim, and Stewart, JJ., concur in the result) reverses the Washington Circuit Court’s order staying an arbitration filed by Hyundai Construction Equipment Americas, Inc., and Hyundai Heavy Industries Co., Ltd. (collectively referred to as “Hyundai”) against Southern Lift Trucks (“Southern”).
In a prior appeal, the Court ruled the language of the arbitration agreement required all of Southern’s claims against Hyundai must be arbitrated except for “any portions of Southern’s declaratory-judgment claim relating to the ‘enforceability of any provision’ of the dealer agreements.” Ms. *3. When Southern failed to initiate an arbitration proceeding, “Hyundai initiated arbitrations concerning its claims against Southern, chiefly concerning counterclaims Hyundai had asserted against Southern in the trial court, as well as additional claims regarding certain Mississippi territories.” Ibid. The trial court then granted Southern’s motion to stop the arbitrations initiated by Hyundai and “temporarily enjoining the parties from proceeding with arbitration pending the resolution of Southern’s declaratory-judgment claim before the trial court.” Ms. *4.
In reversing, the Court holds that the arbitration provision’s “permissive-exception language merely allows a party to seek a declaratory judgment. It is not a limitation on the arbitrators’ otherwise comprehensive jurisdiction… The pendency of the declaratory-judgment action in the trial court, thus, does not prevent the parties from proceeding with arbitration of the arbitrable claims.” Ms. ** 9-11.
The Court rejects Southern’s argument “that the injunction (and stay) is necessary to protect the jurisdiction of the trial court, to prevent inconsistent results, and to promote judicial economy,” Ms. *11, and reiterates a “‘trial court has no discretion to stay arbitration on the grounds of judicial economy, possible inconsistent results, or the existence of non-arbitrable claims.’” Ms. *11, quoting Ex parte Costa & Head (Atrium), Ltd., 486 So. 2d 1272, 1276 (Ala. 1986).
Finally, the Court emphatically rejects Southern’s argument that the Court ruled in the prior appeal that the declaratory judgment claim must be decided in court first:
We ordered arbitration. Southern failed to initiate an arbitration. In fact, not only did Southern fail to initiate an arbitration, it moved to prevent the arbitrations initiated by Hyundai from moving forward. Those actions are inconsistent with the purpose of arbitration, which is to enable a faster and more efficient dispute-resolution process. See AT&T Mobility LLC v. Concepcion, 563 U.S. 333, 344 (2011) (“The point of affording parties discretion in designing arbitration processes is to allow for efficient, streamlined procedures tailored to the type of dispute.”).
Ms. *14.