Federal Courts May Confirm Arbitration Awards in Stayed Cases

Court

U.S. Supreme Ct.

Decided

May 14, 2026

Case No.

25–83

In Jules v. Andre Balazs Properties, a unanimous United States Supreme Court held that a federal court that has stayed claims under section 3 of the Federal Arbitration Act (FAA) keeps jurisdiction to confirm or vacate the resulting arbitral award under sections 9 and 10⁠—⁠even when the confirmation or vacatur motion presents no independent basis for federal jurisdiction on its face. The Court affirmed the judgment of the Second Circuit.

Background

Adrian Jules worked at the Chateau Marmont Hotel in Los Angeles from 2017 to 2020. After the hotel ended his employment during the COVID⁠—⁠19 pandemic, he sued in federal court in New York, alleging that the defendants had discriminated against him in violation of federal and state law.

Jules had signed an arbitration agreement before starting work. Citing that agreement, the defendants moved to stay the federal case under section 3 of the FAA. In 2021, the District Court found the claims arbitrable and stayed the proceedings.

Jules then arbitrated. In 2023, the arbitrator ruled against him on all claims and awarded roughly $34,500 in sanctions to the defendants. Back before the same District Court, the defendants moved to confirm the award under section 9, and Jules cross⁠—⁠moved to vacate under section 10.

Jules argued that, under Badgerow v. Walters, the court lacked jurisdiction because the section 9 and section 10 motions raised no federal question and the parties were nondiverse, with less than $75,000 at stake. The District Court disagreed and confirmed the award, and the Second Circuit affirmed.

What the Court Held on Jurisdiction

Justice Sotomayor, writing for a unanimous Court, explained that assessing jurisdiction over a section 9 or section 10 motion in a case that began in federal court does not require the “looking through” analysis at issue in Vaden v. Discover Bank and Badgerow. The court may instead look at the suit already before it.

The District Court had original jurisdiction over Jules’s federal claims under title 28 United States Code section 1331. That jurisdiction let the court decide arbitrability before staying the case, and nothing in the FAA eliminated it while the parties arbitrated. When the parties returned with section 9 and section 10 motions, the court retained the same jurisdiction it had from the start.

The Court distinguished Badgerow, where the only thing to occur in federal court was the confirm⁠—⁠or⁠—⁠vacate dispute itself, leaving only two places to find jurisdiction. Here, a third source existed: the original federal claims. Because those claims were pending, if stayed, the motions were integral to deciding whether the award would resolve them.

Jules’s Remaining Arguments

The Court rejected Jules’s reading of Badgerow as converting the nonjurisdictional FAA into a comprehensive scheme requiring an independent jurisdictional basis for every section 9 and section 10 motion. The defendants sought no unusual look⁠—⁠through rule; they asked only that the court use the FAA’s tools to resolve claims Jules had filed in federal court under section 1331.

The Court also declined to treat section 9 and section 10 applications as entirely new actions, noting that section 3’s mandatory stay is meant to avoid the costs of a new suit. It found Jules’s reliance on the FAA’s maritime provision, section 8, unavailing, and concluded that his policy concerns about manufactured federal jurisdiction were conjectural.