In Southland v. Keating, the U.S. Supreme Court invalidated a portion of the California Franchise Investment Law, which had been interpreted to require judicial consideration of claims brought under it. The Court held that in enacting the FAA, Congress intended to foreclose attempts to limit the enforceability of arbitration agreements by the States; State law contrary to the FAA violates the supremacy clause of the U.S. Constitution. Chief Justice Burger, writing for the majority, found that in enacting section 2 of the FAA, Congress declared a 'national policy' favoring arbitration and 'withdrew the power of the States to require a judicial forum for the resolution of claims which the parties agreed to resolve by arbitration.' As a result of the Southland case, the quirks and idiosyncracies of State arbitration laws have largely disappeared. The Southland case was not completely unexpected; two Supreme Court cases -- Prima Paint Corp. v. Flood and Conklin Manufacturing Co., and Moses H. Cone Memorial Hospital v. Mercury Construction Co. -- had hinted at preemption, but neither directly addressed the issue of whether the FAA must be applied by State courts. The Southland decision will not radically change the law in States already requiring enforcement of arbitration issues; in States where arbitration clauses have been disfavored, section 2 of the FAA will require enforcement of the agreement, notwithstanding contrary State law. Included are 127 references.