Chilutti v. Uber Techs., Inc., 2026 Pa. LEXIS 79 (January 21, 2026) Brobson, J.
We granted allowance of appeal in this matter to consider whether the Superior Court properly determined that a trial court order granting a petition to compel arbitration of ongoing litigation constitutes an immediately appealable collateral order. If the Court concludes that the Superior Court correctly characterized that order as a collateral order, then we also must examine whether the trial court erred by granting the petition to compel arbitration. After careful review, we hold that the trial court’s order does not qualify as a collateral order. We, therefore, do not reach the second question. Instead, we vacate the Superior Court’s judgment and remand the case to that court with instructions to quash the appeal.
Generally speaking, Pennsylvania’s appellate courts have jurisdiction to entertain appeals from the final orders of trial courts. Pa.R.A.P. 341(a). Typically, a final order disposes of all claims and all parties. Pa.R.A.P. 341(b)(1). “The final order rule reflects the long-held limitation on review by both federal and [S]tate appellate courts. Considering issues only after a final order maintains distinctions between trial and appellate review, respects the traditional role of the trial judge, and promotes formality, completeness, and efficiency.” Shearer v. Hafer, 177 A.3d 850, 855 (Pa. 2018). Here, the trial court’s order indisputably was not final, as it merely granted Uber’s petition to compel arbitration and stayed further court proceedings until the completion of arbitration. In other words, the order did not dispose of all claims or all parties.
As Uber points out, the General Assembly unambiguously aimed Section 7341 of the Judicial Code’s limited standard of review solely at the “award of the arbitrator in a nonjudicial arbitration.” See 42 Pa. C.S. § 7341 (“The award of an arbitrator in a nonjudicial arbitration . . . is binding and may not be vacated or modified unless it is clearly shown that a party was denied a hearing or that fraud, misconduct, corruption or other irregularity caused the rendition of an unjust, inequitable or unconscionable award.”) (emphasis added). In other words, pursuant to the plain language of Section 7341, the limited standard of review for common law arbitration applies to arbitrators’ awards, not to trial courts’ decisions or orders. Of further note, Section 7342(a) of the Judicial Code provides that specific sections of the Revised Statutory Arbitration Act, 42 Pa. C.S. §§ 7321.1-.31, apply to common law arbitration, including Sections 7321.8 and 7321.29. 42 Pa. C.S. § 7342(a).
Here, in response to the Chiluttis’ complaint, Uber filed a petition to compel arbitration, contending, inter alia, that Uber and the Chiluttis have an arbitration agreement. Uber further averred that the Chiluttis ignored that agreement and, instead, pursued an action in the trial court. The trial court granted the petition, stayed the trial court proceeding, and ordered the parties to arbitrate. If the Chiluttis are later aggrieved by the final judgment that the trial court enters after the matter is returned to that court following arbitration, then the Chiluttis can appeal that judgment to the Superior Court. In that appeal, the Chiluttis also can challenge, among other things, the trial court’s April 26, 2021, order that is the subject of this appeal. See, e.g., Betz v. Pneumo Abex, LLC, 44 A.3d 27, 54 (Pa. 2012) (stating that “an appeal of a final order subsumes challenges to previous interlocutory decisions”). Whether the trial court erred by granting Uber’s petition to compel arbitration presents a question of law. Consequently, should the Chiluttis appeal from the trial court’s final judgment and challenge the trial court’s order compelling arbitration, the Superior Court’s standard of review would be de novo, not the standard for judicial review of an arbitration award. See, e.g., Santiago v. Philly Trampoline Park, LLC, 343 A.3d 995, 1003 (Pa. 2025) (explaining that enforceability of arbitration agreement presents question of law, “over which our standard of review is de novo and the scope of review is plenary”).
We hold that the trial court’s order granting Uber’s petition to compel arbitration and staying court proceedings does not qualify as a collateral order. The Superior Court erred in holding to the contrary and, therefore, lacked jurisdiction to entertain the merits of the Chiluttis’ substantive claim regarding the parties’ alleged lack of a valid arbitration agreement. Consequently, we vacate the Superior Court’s judgment and remand the matter to that court with instructions to quash the Chiluttis’ appeal.
Chief Justice Todd and Justices Donohue, Dougherty, Wecht and Mundy join the opinion. Justice McCaffery did not participate in the consideration or decision of this matter.
• The Supreme Court vacated the Superior Court judgment and remanded the case to that court with instructions to quash an interlocutory appeal.
• Superior Court determined that a trial court order granting a petition to compel arbitration of ongoing litigation constitutes an immediately appealable collateral order.
• The Superior Court was wrong in the view of the Supreme Court.
