S.A. Mineracao da Trinidade-Samitri v. Utah Int'l, Inc.

In 1974 S.A. Mineracao da Trinidade-Samitri (Samitri) (plaintiff), a Brazilian corporation, entered into a series of agreements with several international corporations, including Utah International, Inc. (Utah), related to investments in ore mining. The agreements contained an arbitration provision stating that “whenever any question or dispute shall arise or occur under this [agreement], such question or dispute shall . . . be finally settled by arbitration in Paris, France.” The parties entered into several subsequent agreements, which the district court later determined were supplements to the original agreements containing the arbitration clauses. Samitri alleged that Utah had fraudulently induced Samitri to enter into the international iron-ore-mining venture and filed 17 different claims against Utah in federal district court. Utah moved to stay the action and compel arbitration. Samitri cross-moved to enjoin arbitration. The district court compelled arbitration of all of Samitri’s claims except two brought under the Racketeer Influenced and Corrupt Organizations Act (RICO), which the district court stayed pending completion of the arbitration proceedings. Samitri appealed, arguing that (1) the arbitration clauses were not broad enough to include Samitri’s claims of fraudulent inducement; (2) the arbitration clauses in the original agreements did not encompass Samitri’s claims arising from subsequent agreements between the parties; and (3) the RICO claims should not have been stayed pending arbitration.