Just in time to participate in Arbitration Nation’s (unplanned) series on legislative nullification of arbitration agreements, the Ninth Circuit Court of Appeals ruled last week that the Carmack Amendment nullifies pre-dispute arbitration agreements in interstate shipment contracts. Smallwood v. Allied Van Lines, Inc., ___ F.3d ___, 2011 WL 4927404 (9th Cir. 2011). The Ninth Circuit