We'll hear argument next in case 22, 1218, Smith v. Spisari. Mr. Geiser.

Thank you, Mr. Chief Justice, and may it please the Court. Section 3 unambiguously mandates a stay pending arbitration, and the FAA's plain text, structure, and purpose confirm that conclusion.

Congress directed that a Court shall stay the trial of the action until the

arbitration is complete. There is no mention of dismissal, and there are no exceptions for cases

where all claims are subject to arbitration. If a court ignores that command and dismisses,

it activates a premature right to appeal contrary to the FAA's reticulated scheme.

It eliminates the essential backdrop that protects litigant rights if a party compels arbitration

but abandons the arbitration process, which has happened in this very case.

And critically, it invites wasteful disputes that pointlessly burden parties in courts as litigants fight over

whether to stay or dismiss and then take appeals over whether to stay or dismiss.

A bright line rule answers that procedural question in a manner that best preserves judicial

and party resources and directly advances the core purpose of the FAA itself, eliminating waste, avoiding

unnecessary litigation, and sending parties to arbitration as quickly as possible.

I welcome the Court's questions.

Mr. Geiser, what difference does it make to grant a stay here or dismissal without prejudice?

Well, it makes a big difference whether we have a suit to come back to.

The arbitration has now failed.

The respondents have not paid their fees.

Our clients will have to file new suits, engage in new service, do new case-initiating

documents, and waste our time in the Court's time.

We also face a situation where respondents could then move to compel arbitration again.

But aren't you also encouraging people to start out in federal court?

...