In Rem – Paul Mollica's Federal Courts Blog

Citing the Probate Exception, Sixth Circuit Holds District Court Lacked Equitable Jurisdiction to Compel Arbitration of Action Proceeding In Rem in State Court

In Johnson v. Johnson, No. 24-2058 (6th Cir. Oct. 24, 2025), the Sixth Circuit affirms dismissal of an action to compel arbitration under Section 4 of the Federal Arbitration Act, holding that – under the probate exception – the lower court lacked equitable jurisdiction to interfere with a state in rem proceeding. The decedent “Mrs.Continue reading “Citing the Probate Exception, Sixth Circuit Holds District Court Lacked Equitable Jurisdiction to Compel Arbitration of Action Proceeding In Rem in State Court”