In response to what the United States Congress perceived as “judicial hostility” to arbitration, Congress passed the Federal Arbitration Act1 in 1925 to ensure that arbitration agreements were on an equal footing with other contracts. In fact, the Act has been widely interpreted to ensure a “liberal federal policy favoring arbitration.”2 The trend favoring arbitration has been especially pronounced in recent years, with the United States Supreme Court the chief promoter of ar