TEXAS BRINE COMPANY, L.L.C., Plaintiff — Appellant v. AMERICAN ARBITRATION ASSOCIATION, INCORPORATED; ANTHONY M. DILEO; CHARLES R. MINYARD, Defendants — Appellees, 955 F.3d 482

Summary

HOLDINGS: [1]-Where claims that two arbitrators hid conflicts of interest were the basis on which a state court vacated an arbitral award, and where the aggrieved party then sued in state court, and where an out-of-state defendant removed the case to federal court before the in-state defendants were served, removal was proper under 28 U.S.C.S. § 1441; [2]-The forum-defendant rule did not prohibits a non-forum defendant from removing a case when a not-yet-served defendant was a citizen of the forum state, § 1441(b)(2) was inapplicable until a home-state defendant had been served, and until then, a state court suit was removable under § 1441(a) so long as the federal court had jurisdiction over the action; [2]-Judgment on the pleadings was warranted because the FAA provided the exclusive remedy for complaints of arbitrator bias or for a corrupt arbitrator's conduct.