"From Munro and Dorman, taken together, one can glean that the Federal Arbitration Act's support for arbitration agreements is alive and well ... While the defendants failed to compel arbitration in Munro, their defeat was technical rather than substantive.... The Ninth Circuit's opinion notably eschewed the anti-arbitration effusions of the court below and instead concentrated on the question of what party's consent was needed to create an enforceable arbitration agreement. The obvious lesson is that arbitration clauses are most effective when included in the terms of the plan rather than left to individual participants' employment agreements."  MORE >>