Coinbase v. Suski
The Facts
Coinbase users agreed to a user agreement containing an arbitration clause with a delegation provision and a separate Coinbase-sponsored sweepstakes agreement with no delegation clause. When users brought class claims, Coinbase argued the delegation clause in the user agreement required an arbitrator to decide arbitrability. Lower courts were split.
The Application
Here the Court applied this principle to resolve the contractual overlap: when Coinbase users sued over the sweepstakes agreement, the relevant contract governing that dispute contained no delegation clause, even though their user agreement did. The Court held that Coinbase could not invoke the user agreement's delegation provision to bypass judicial review of arbitrability for claims arising solely under the sweepstakes terms. Because the parties had not clearly signaled an intent for the user agreement's delegation clause to govern disputes under the separate sweepstakes contract, courts retained the threshold task of determining which contract applied before any arbitrator could take the delegation question.
The Conclusion
**Unanimous ruling: courts, not arbitrators, decide which contract applies before deferring to a delegation clause.** Coinbase's delegation argument rejected for sweepstakes claims.
No circuit court data for this case.
Case Analysis
Overview
The Supreme Court held unanimously that when two contracts exist -- one containing an arbitration clause with a delegation provision and one without -- courts must determine which contract governs the specific dispute before enforcing the delegation clause. A delegation clause in one contract does not automatically delegate gateway arbitrability questions arising under the other.
Facts
Coinbase users agreed to a user agreement containing an arbitration clause with a delegation provision and a separate Coinbase-sponsored sweepstakes agreement with no delegation clause. When users brought class claims, Coinbase argued the delegation clause in the user agreement required an arbitrator to decide arbitrability. Lower courts were split.
Issue
Whether a delegation clause in one contract controls arbitrability of disputes arising under a related contract that contains no delegation clause, requiring the arbitrator rather than the court to resolve gateway questions.
Rule
Courts must first identify which contract governs a given dispute; a delegation clause in one contract does not extend to disputes governed by a separate, related contract absent clear evidence the parties intended otherwise.
Analysis
Here the Court applied this principle to resolve the contractual overlap: when Coinbase users sued over the sweepstakes agreement, the relevant contract governing that dispute contained no delegation clause, even though their user agreement did. The Court held that Coinbase could not invoke the user agreement's delegation provision to bypass judicial review of arbitrability for claims arising solely under the sweepstakes terms. Because the parties had not clearly signaled an intent for the user agreement's delegation clause to govern disputes under the separate sweepstakes contract, courts retained the threshold task of determining which contract applied before any arbitrator could take the delegation question.
Conclusion
**Unanimous ruling: courts, not arbitrators, decide which contract applies before deferring to a delegation clause.** Coinbase's delegation argument rejected for sweepstakes claims.
Notes
OT2023. Added via SCOTUS bulk import 2026-05-14
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