Asklemmy

I'm familiar with it through Circuit City Stores, Inc. v. Adams, which is about employment arbitration. The majority argued that it was the "natural reading" that the Federal Arbitration Act intended to cover employment arbitration agreements. The dissent goes through the legislative history of the Act to establish that no one in 1925 intended the federal arbitration act to cover employment agreements. There is probably a lot more caselaw to this Act than just employment arbitration, but that's what my 1L paper was on.

Dissent quoted below:

The history of the Act, which is extensive and well documented, makes clear that the FAA was a response to the refusal of courts to enforce commercial arbitration agreements, which were commonly used in the maritime context. The original bill was drafted by the Committee on Commerce, Trade, and Commercial Law of the American Bar Association (ABA) upon consideration of “the further extension of the principle of commercialarbitration.” Report of the Forty-third Annual Meeting of the ABA, 45 A.B.A. Rep. 75 (1920) (emphasis added). As drafted, the bill was understood by Members of Congress to “simply provid[e] for one thing, and that is to give an opportunity to enforce an agreement in commercial contracts and admiralty contracts.” 65 Cong. Rec.1931 (1924) (remarks of Rep. Graham) (emphasis added).^2^ It is no surprise, then, that when the legislation  126 was first introduced in 1922,^3^ it did not mention employment contracts, but did contain a rather precise definition of the term “maritime transactions” that underscored the commercial character of *1315 the proposed bill.^4^ Indeed, neither the history of the drafting of the original bill by the ABA, nor the records of the deliberations in Congress during the years preceding the ultimate enactment of the Act in 1925, contain any evidence that the proponents of the legislation intended it to apply to agreements affecting employment.

. . .

The irony of the Court's reading of § 2 to include contracts of employment is compounded by its cramped interpretation of the exclusion inserted into § 1. As proposed and enacted, the exclusion fully responded to the concerns of the Seamen's Union and other labor organizations that § 2 might encompass *129 employment contracts by expressly exempting the labor agreements not only of “seamen” and “railroad employees,” but also of “any other class of workers engaged in foreign or interstate commerce.” 9 U.S.C. § 1 (emphasis added). Today, however, the Court fulfills the original—and originally unfounded—fears of organized labor by essentially rewriting the text of § 1 to exclude the employment contracts solely of “seamen, railroad employees, or any other class of [transportation] workers engaged in foreign or interstate commerce.” See ante, at 1311. In contrast, whether one views the legislation before or after the amendment to § 1, it is clear that it was not intended to apply to employment contracts at all.

++Cir. City Stores, Inc. v. Adams++, 532 U.S. 105, 125–26, 121 S. Ct. 1302, 1314–15, 149 L. Ed. 2d 234 (2001)