Badgerow v. Walters
Issues
Do federal courts have jurisdiction to decide post-award arbitration claims when subject-matter jurisdiction is based solely on an undisputed federal claim?
This case asks the Supreme Court to determine to what extent proceedings to vacate or enforce an award under the Federal Arbitration Act (“FAA”) belong in federal court. The Supreme Court has previously decided that motions to compel arbitration can be heard in federal court if there is a federal question when the court “looks through” to the underlying claim. Denise Badgerow contends that the Supreme Court’s look-through approach does not apply to post-award proceedings; in her view, a plain reading of the FAA deprives federal district courts of jurisdiction to adjudicate post-award claims. Walters counters that federal district courts have subject-matter jurisdiction in such instances, and that a motion to vacate an arbitration award does not deprive federal courts of subject-matter jurisdiction over underlying controversies. The outcome of this case has serious implications for future parties to arbitration proceedings under the FAA and for the federal district courts’ authority to enforce arbitration awards.
Questions as Framed for the Court by the Parties
Whether federal courts have subject-matter jurisdiction to confirm or vacate an arbitration award under Sections 9 and 10 of the Federal Arbitration Act when the only basis for jurisdiction is that the underlying dispute involved a federal question.
From January 2014 to July 2016, Denise A. Badgerow worked as an associate financial advisor for REJ Properties, Inc (“REJ”). Badgerow v. Walters at 2.