3M Company (“3M”) and Amtex Security, Inc. (“Amtex”) entered into two agreements, a master agreement and a sub-agreement. While the sub-agreement contained an arbitration provision, the master agreement did not. Despite their titles, the parties agreed that the sub-agreement controlled to the extent the two agreements conflicted. A dispute arose, and Amtex filed a complaint in Texas state court. 3M removed the case to federal district court, demanded arbitration and filed a motion to compel arbitration in federal district court in Minnesota. Amtex then filed an amended complaint that included fraud claims and requested punitive damages. The district court in Texas granted 3M’s motion to stay pending a decision by the court in Minnesota as to whether the disputes should be arbitrated. The Minnesota district court granted 3M’s motion to compel arbitration, and Amtex appealed.
In affirming, the Eighth Circuit ruled that the order compelling arbitration is final and appealable since the motion to compel arbitration was the only matter brought before the Minnesota district court. In affirming the order of the district court, the court reasoned that the definitions of the terms in the arbitration agreement indicated an intent to arbitrate a broad range of disputes. The court then looked to the underlying factual allegations in the amended complaint and determined that the broad scope of the arbitration clause could cover each of Amtex’s claims. 3M Co. v. Amtex Sec., Inc., No. 07-3519 (8th Cir. Sept. 16, 2008).