The Tennessee Court of Appeals affirmed confirmation of an arbitration award issued in favor of a credit card issuer even though the cardholder presented a separate arbitration award in his favor because only the award in favor of the issuer was obtained in accordance with the cardmember agreement.

In MBNA America Bank, N.A. v. Baker, No. M2004-02239-COA-R3-CV, 2007 WL 3443600 (Tenn. Ct. App. Nov. 15, 2007), Baker had an unpaid balance on his MBNA credit card. MBNA attempted to collect, but Baker withheld payment, which led to two arbitration proceedings.

Baker filed an arbitration claim with an entity known as the American Arbitration Forum (AAF). This entity granted a "default judgment" in Baker's favor. MBNA filed an arbitration claim with the National Arbitration Forum (FORUM), the arbitration administrator named in Baker's cardmember agreement. The FORUM arbitrator issued an award in MBNA's favor.

MBNA filed a court action seeking confirmation of the FORUM award. Baker cited the AAF award in opposing confirmation. The trial court confirmed the award.

On appeal, the Court held that the trial court properly confirmed the award because the "[t]he cardholder agreement clearly call[ed] for arbitration to be conducted by the National Arbitration Forum." In reaching its holding, the Court did not address various arguments raised by Baker, describing them as "convoluted."