Scope of Federal Court Jurisdiction to Confirm or Vacate Arbitration Awards — Adrian Jules v. Andre Balazs Properties

Adrian Jules v. Andre Balazs Properties, et al.

25-83docketfromUnited States Court of Appeals for the Second Circuit

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Granted

Dec 5, 2025

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Argued

Mar 30, 2026

Pending

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Current status: argued

What the Court agreed to answer

Under Sections 9 and 10 of the Federal Arbitration Act, a party may apply to confirm or vacate an arbitration award. But federal courts have limited jurisdiction over Section 9 and 10 applications. In Badgerow v. Walters, 596 U.S. 1, 4, 9-11 (2022), this Court held that a federal court may exercise jurisdiction only if the application establishes diversity or federal-question jurisdiction on its face. A federal court may not exercise jurisdiction merely on the basis that the underlying dispute, save for the arbitration agreement, would have been justiciable in federal court. See id. But what happens when a court initially exercises jurisdiction over the underlying dispute, stays the case pending arbitration, and is later faced with an application to confirm or vacate an arbitration award in the same case? The courts of appeals have sharply divided on the appropriate jurisdictional analysis. Several courts of appeals, including the Second Circuit below, have held that the initial exercise of jurisdiction creates a "jurisdictional anchor" that confers jurisdiction over a subsequent Section 9 or 10 application to confirm or vacate, even if jurisdiction would otherwise be absent. By contrast, the Fourth Circuit has held that a court must establish an independent basis for jurisdiction over a Section 9 or 10 application to confirm or vacate. The question presented is: Whether a federal court that initially exercises jurisdiction and stays a case pending arbitration maintains jurisdiction over a post-arbitration Section 9 or 10 application where jurisdiction would otherwise be lacking.

Scope of Federal Court Jurisdiction to Confirm or Vacate Arbitration Awards — Adrian Jules v. Andre Balazs Properties

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Scope of Federal Court Jurisdiction to Confirm or Vacate Arbitration Awards — Adrian Jules v. Andre Balazs Properties

To decide when federal courts can hear motions to confirm or vacate arbitration awards

To decide when federal courts can hear motions to confirm or vacate arbitration awards