Arbitration is another one of the more popular forms of ADR, though proceedings are more formal and more akin to a court proceeding than those in mediation. Arbitration can be either voluntary or mandatory; mandatory arbitration proceedings are usually imposed by statute or by a contract you have voluntarily entered into. Arbitration is generally binding, though there are forms of nonbinding arbitration. In Tuetken v. Tuetken, 320 S.W. 262 (Tenn. 2010), the Tennessee Supreme Court held that parties may not submit custody issues to binding arbitration. Parties are able to submit custody issues to non-binding arbitration pursuant to Rule 31 of the Tennessee Rules of Civil Procedure.