of orders—all typically occurring in litigation over arbitration—which in addition to more mainstream rulings, are to be treated as appealable.” Id. at 78 (emphasis added). Such jurisdictions also recognize that it would be fundamentally unfair to “require a party who has not agreed to arbitrate a particular dispute ... to arbitrate it.” Kremer, 788 N.W.2d at 549. Even in the majority of the decisions cited by Petitioners, courts do not conclude that statutes based on the UAA or RUAA are exclusive. Instead, those decisions conclude that (1) orders compelling arbitration are not listed under the RUAA appeals provision, and (2) that the appealability of orders compelling arbitration “must also be examined” under that jurisdiction’s general appeals statute. Chem-Ash, 751 S.W.2d at 354 (<HOLDING>). Consequently, even the states that hold
holding that where the trial court had referred the parties to arbitration but it was ambiguous as to whether the court had also dismissed the underlying case dismissal and referral to arbitration should really be construed as an order to stay litigation pending arbitration which under koczak and umana was not a final appealable order holding that elearly if the legislature had intended to deny or delay arbitration by permitting an appeal from an order compelling arbitration it would have said so but also holding that even so the trial courts order must also be examined in light of rule 2a of the arkansas rules of appellate procedure which governs the appealability of lower court orders emphasis added holding that an order compelling arbitration in an independent proceeding is appealable as a final order because in that context the order compelling arbitration resolves the sole issue before the court holding that an order remanding an arbitration award is not a final appealable order when the order does not also vacate the arbitration award holding that orders compelling arbitration are not appealable not because of the uaa appeals provision but because it has been definitely settled by the supreme court of this state that an order compelling arbitration is not final and therefore is not appealable