Teamsters Local 177 v. United Parcel Service, No. 19-3150 (3d Cir. 2020)
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The Union sought confirmation of an arbitration award under the Federal Arbitration Act, 9 U.S.C. 9. Section 9 provides that a district court “must grant” a confirmation order for an award upon application where the award has not been “vacated, modified, or corrected” under the Act. UPS, the loser in arbitration, opposed confirmation and filed a cross-motion to dismiss, arguing that the district court did not have subject-matter jurisdiction because there was no case or controversy as required by Article III of the Constitution, given that UPS agreed to abide by the award and corrected any subsequent violations.
The Third Circuit reversed. The district court had subject matter jurisdiction to confirm the award even in the absence of a new dispute about it. The confirmation of an arbitration award is a summary proceeding that merely makes what is already a final arbitration award a judgment of the court. Confirmation is the process through which a party to arbitration completes the award process under the Act, as the award becomes a final and enforceable judgment, 9 U.S.C. 13. The Act not only authorizes but mandates, that district courts confirm arbitration awards by converting them into enforceable judgments through a summary proceeding.
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