For example, under French law, bankruptcy matters are inarbitrable. International arbitrations are governed also by municipal procedural law, most frequently by the law of the jurisdiction in which the arbitral tribunal sits. This law, known as the lex loci arbitri , may be crucial in resolving procedural issues that arise. Thus, arbitral tribunals often meet in a jurisdiction with an arbitration law that is both developed and supportive of arbitration as a dispute resolution mechanism. In the United States, both state and federal law govern international arbitration.
Many states have their own state statutes on arbitration generally.
Whereas a few states, such as New York, drafted original arbitration laws, many states have adopted arbitration laws based on the Uniform Arbitration Act, itself modeled on the Federal Arbitration Act. In addition, several states, including Florida, California, Georgia, Texas and Connecticut have adopted special statutes for international arbitration. It is a relatively narrow statute that focuses on the relationship of the courts to the arbitral process. The recent United States Supreme Court decisions of Allied-Bruce Terminix Companies, Inc. v. Dobson and Doctor's Associates, Inc. v. Casarotto have emphasized that in all cases involving interstate commerce, the FAA preempts conflicting state law.