the validity of these three categories of challenge in its more-recent decision of Rent-A-Center, West, Inc. v. Jackson, 561 U.S. 63, 70, 70 n. 2, 130 S.Ct. 2772, 177 L.Ed.2d 403 (2010); see also Rowe, 932 So.2d at 539 (inferring from the above-cited United States Supreme Court decisions that there are three categories of challenges to an arbitration agreement). We therefore conclude that there are three categories of challenge to an arbitration clause: (1) a challenge specific to the arbitration provision itself; (2) a challenge to the contract as a whole that would invalidate the contract after an agreement has been reached, such as fraud, duress, or a contractual provision (other than the arbitration provision itself) that is contrary to public policy, see Shotts, 86 So.3d at 480-81 (<HOLDING>); and (3) a challenge to the contract as a
holding that whether in federal or state court a challenge to the validity of the contract as a whole and not specifically to the arbitration clause within it must go to the arbitrator and not the court holding that an arbitration award based on the conclusion that unappended waiver forms are unenforceable pursuant to public policy is not reviewable by the courts because as stated in schultz it is not based on an allegation that a specific provision in an insurance policy contravenes public policy holding that the trial court not the arbitrator must decide a challenge to an arbitration provision based on public policy holding that while the determination of the scope of an arbitration agreement is for the court the enforcement of pleading requirements before the arbitrator is a procedural matter for the arbitrator holding that upon vacating an arbitration award the court has the discretion to remand to the same arbitrator or different arbitrator