In its 2010 decision in Stolt-Nielsen SA v. AnimalFeeds International Corp., 559 U.S. 662 (2010), the U.S. Supreme Court held that an arbitrator may employ class procedures only if the parties agreed to them. In Oxford Health Plans LLC v. Sutter, 133 S. Ct. 2064 (2013) (No. 12-135), the Supreme Court reaffirmed that holding, but applied the narrow review standard of the Federal Arbitration Act (“FAA”) to uphold an arbitrator’s decision that the parties had consented to class arbitration. In Oxford, the parties had agreed the arbitrator should decide whether the contract authorized class arbitration. The arbitrator concluded it did, and reaffirmed its decision after Stolt-Nielsen. The Third Circuit upheld the arbitrator’s ruling, and the Supreme Court affirmed. It stated that the question was whether the arbitrator arguably interpreted the parties’ contract, not whether he got it right or wrong. Because the parties had agreed that the arbitrator should determine whether the contract authorized class procedures, and the arbitrator had interpreted the contract, the decision was affirmed. The Court noted that the issue would be different if the availability of class arbitration was a question of arbitrability. Certain gateway matters, such as whether there is a valid arbitration agreement or whether a binding arbitration clause applies to a type of controversy “are presumptively for courts to decide.”