The question
Whether a federal court that previously stayed claims in a pending action under Section 3 of the Federal Arbitration Act has jurisdiction to confirm or vacate the resulting arbitral award under Sections 9 and 10, even when the confirm or vacate motion does not independently present a basis for federal jurisdiction on its face.
Jules v. Andre Balazs Properties
What the Court decided
The Court affirmed that a federal court retains jurisdiction to confirm or vacate an arbitral award under Sections 9 and 10 of the FAA when that court had already stayed the underlying claims under Section 3. The court's original jurisdiction over the federal claims that were filed and stayed extends to the later motions, so no independent jurisdictional basis on the face of the motion is required. Because the original claims supply a third place to look for jurisdiction, the case is unlike Vaden and Badgerow, where the confirm-or-vacate dispute was the only matter before the court.
How the justices split
UnanimousThe Court's opinion
Sotomayor, joined by Roberts, Thomas, Alito, Kagan, Gorsuch, Kavanaugh, Barrett, Jackson
A district court that had original jurisdiction under 28 U.S.C. 1331 over the federal claims, and that stayed those claims under Section 3 pending arbitration, retains that jurisdiction to decide the later Section 9 and Section 10 motions. Assessing jurisdiction over such a motion in a case originally filed in federal court does not require looking through the motion to the underlying substantive controversy, because the court can look to the original claims already before it. This distinguishes Vaden and Badgerow, where the confirm-or-vacate dispute was the only matter in federal court and the only places to look were the face of the motions or the underlying dispute not before the court.
How we know · 5 sourced claims
The Court held that a federal court that previously stayed claims under Section 3 of the FAA has jurisdiction to confirm or vacate the resulting arbitral award under Sections 9 and 10.
Source: syllabus, Held
The district court had original jurisdiction over Jules's federal claims under 28 U.S.C. 1331, and that jurisdiction extended to the later Section 9 and Section 10 motions.
Source: syllabus, Held
The Court distinguished this case from Vaden v. Discover Bank and Badgerow because the original claims provided a basis for jurisdiction that was not present in those cases.
Source: syllabus, Held
Justice Sotomayor delivered the opinion for a unanimous Court.
Source: syllabus, lineup
The case arose on certiorari to the United States Court of Appeals for the Second Circuit.
Source: syllabus, Held