In Delta Pine Land Company v. Monsanto Company, download file, the Chancery Court read two related agreements together to conclude that the parties intended to arbitrate the issues raised. The Vice Chancellor refused to distinguish a recent Chancery Court opinion in Willie Gary, LLC v. James and Jackson, LLC, summarized here on this blog, which discussed the applicable standards about enforceability of arbitration clauses in great detail.
Unlike the Willie Gary case, the court found that the instant arbitration clauses did not have a “carve out” for injunctive relief.