The Fourth Circuit and a Minnesota judge have ruled for municipalities who want to arbitrate claims that investment banks rigged the market, while two New York district judges have sided with investment banks.

On Monday it appeared that split might run right through the Ninth Circuit as well, with Judge Jay Bybee sounding inclined to agree with Goldman Sachs & Co. that a forum selection clause requires the city of Reno's claims be heard in federal court — where they will likely be barred by the statute of limitations.