Reed Bates and Stephen Still recently secured a reversal by the Eighth Circuit Court of Appeals of a United States District Court Order dismissing a 9 U.S.C. 4 Complaint to Compel Arbitration for lack of subject matter jurisdiction. In Northport Health Services of Arkansas, LLC, et al. v. Wayne Rutherford, - - F.3d - -, 2010 WL 1929777 (8th Cir. May 14, 2010), the Eighth Circuit, in two nursing home wrongful death actions consolidated for appeal, compelled arbitration pursuant to 9 U.S.C. 4 and reversed the United States District Court for the Western District of Arkansas' finding that it lacked subject matter jurisdiction pursuant to Vaden v. Discover Bank, 129 S. Ct. 1262 (2009).