In Omstead v. Dell, Inc., 594 F.3d 1081 (9th Cir. 2010), the Ninth Circuit had held that a plaintiff, against whom the district court had entered an order compelling arbitration, could take an appeal from that otherwise unappealable order by dismissing all his claims with prejudice. Now, reviewing that same question in light of Microsoft Corp. v. Baker (2017) 137 S.Ct. 1702, the court holds that the voluntary dismissal of claims cannot turn an unappealable interlocutory order into an appealable final judgment. Generally, a later Ninth Circuit panel must follow the rule stated by a prior published panel opinion. But that isn’t true when the Supreme Court has meanwhile rendered a decision that either directly overrules the rule stated by the prior panel opinion or when the reasoning of the Supreme Court’s decision is irreconcilable with that of the prior panel opinion.