
MONTH-IN-BRIEF (May 2026)
U.S. Supreme Court Addresses Key Jurisdictional Question Regarding Ability to Confirm or Vacate an Arbitral Award in the Absence of Federal Subject Matter Jurisdiction
By Leslie A. Berkoff, Partner and Chair of Dispute Resolution Practice Group, Moritt Hock & Hamroff LLP
In Jules v. Andre Balazs Properties, 608 U.S. ___ (2026), the United States Supreme Court held that a federal court that had previously stayed litigation pending arbitration under Section 3 of the Federal Arbitration Act (“FAA”) retains jurisdiction to confirm or vacate the resulting award under Sections 9 and 10 of the FAA, even where the confirmation or vacatur motions themselves do not independently establish federal subject matter jurisdiction.
In Jules, a former employee of Chateau Marmont Hotel (“CMH”) filed discrimination claims in federal district court. In response, CMH invoked the arbitration agreement and obtained a stay of the litigation under Section 3 of the FAA. The arbitrator ruled against the employee and awarded CMH sanctions. Thereafter, CMH returned to federal court seeking to confirm the award, while the employee moved to vacate the award (under Sections 9 and 10 of the FAA respectively).




