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ESAB Automation, Inc. v. Hesco Sales, Inc.

Citations: 582 So. 2d 810; 1991 Fla. App. LEXIS 7025; 1991 WL 134368Docket: No. 91-1125

Court: District Court of Appeal of Florida; July 23, 1991; Florida; State Appellate Court

Narrative Opinion Summary

The court has reversed a non-final order denying ESAB Automation, Inc.'s motion to compel arbitration in a breach of contract and warranty action brought by Hesco Sales, Inc. regarding a robotic welder sale. The purchase agreement explicitly required arbitration of any disputes in Fort Collins, Colorado, and the Florida Arbitration Act was deemed inapplicable since arbitration was designated to occur outside Florida. The controversy was determined to involve interstate commerce, thus falling under the Federal Arbitration Act (9 U.S.C. § 2). The record established that the robotic welder was shipped from Colorado to Florida following Hesco's order, and there was correspondence between the parties regarding warranty issues, which stipulated that any warranty claims would necessitate returning the welder to Colorado. The facts were undisputed, leading to the reversal of the trial court's order and remanding the case with directives to compel arbitration.

Legal Issues Addressed

Arbitration Clause Enforcement

Application: The court reversed the trial court's decision and enforced the arbitration clause requiring disputes to be arbitrated in Fort Collins, Colorado.

Reasoning: The court has reversed a non-final order denying ESAB Automation, Inc.'s motion to compel arbitration in a breach of contract and warranty action brought by Hesco Sales, Inc. regarding a robotic welder sale.

Contractual Obligations in Interstate Transactions

Application: The contractual agreement required arbitration in Colorado, reflecting the interstate nature of the transaction, supported by the shipping of the welder from Colorado to Florida.

Reasoning: The record established that the robotic welder was shipped from Colorado to Florida following Hesco's order, and there was correspondence between the parties regarding warranty issues, which stipulated that any warranty claims would necessitate returning the welder to Colorado.

Federal Arbitration Act Applicability

Application: The court determined that the Federal Arbitration Act applies because the transaction involved interstate commerce.

Reasoning: The controversy was determined to involve interstate commerce, thus falling under the Federal Arbitration Act (9 U.S.C. § 2).

Inapplicability of Florida Arbitration Act

Application: The court found the Florida Arbitration Act inapplicable because the arbitration was to occur outside Florida.

Reasoning: The Florida Arbitration Act was deemed inapplicable since arbitration was designated to occur outside Florida.