A Fifth Circuit panel has found a settlement dispute between two pipe companies should have been required to go through arbitration in a decision that could be extended to other arbitration clauses using the same language.

In its unanimous decision, published March 30, the four-judge panel reversed an earlier order from a trial judge in the Southern District of Texas, finding that the language requiring that "any action arising out of" the settlement agreement go through arbitration qualified as a broad clause that applied to the case in question.