We recently reported on the Sixth Circuit’s trends concerning arbitration, and generally these cases arise against a backdrop of a contractual arbitration provision that one party is seeking to enforce.  In Knall Beverage Inc. v. Teamsters Local Union No. 293, the Sixth Circuit again ordered arbitration but did so in an unusual backdrop.  Pursuant to the Multi-Employer Pension Plan Amendments Act, disputes about reallocation liability are subject to mandatory (statutory) arbitration.  In this case, the plaintiffs initially commenced arbitrations to dispute the amount of reallocation liability assessed by trustees and later filed a civil proceeding in court.  The district court ultimately dismissed the complaint as subject to arbitration, prompting this appeal.  The Sixth Circuit wasted little time with these issues concluding: “The determination of whether of plaintiffs are subject to reallocation liability is however straightforwardly subject to mandatory arbitration by the act.”  The Court accordingly rejected plaintiff’s “strained argument”, instead preferring to uphold Congress’ apparent desire to direct these types of disputes to mandatory arbitration.  Although the Sixth Circuit has previously recognized certain circumstances in which the parties may skip the arbitration and proceed directly to federal court, this case did not fall within those confines as the Court declined the plaintiff’s invitation to create a new exception to the otherwise mandatory arbitration process.