A Louisiana appellate court determined that Federal arbitration law governed the parties' dispute, and the lower court erred in refusing to confirm the arbitration award based on lack of jurisdiction under a Louisiana statute.

In Chase Bank USA, N.A., v. Roach, No. 07-1172, 2008 WL 585095 (La. Ct. App. March 5, 2008), Roach, a resident of Lafayette, Louisiana, defaulted on her credit card payments to Chase. The credit card agreement included an agreement to arbitrate under the National Arbitration Forum Code of Procedure.

Chase filed a claim for the delinquent credit card payments. Despite being sent two notices prior to the award proceeding, Roach did not respond or appear. The arbitrator issued an award in favor of Chase.

Roach was sent notice of the award, but she did not respond or communicate with Chase. Next, Chase sent Roach a demand letter that identified the arbitration award and the credit card account upon which it was based.

Following, Chase filed a petition to confirm the arbitration award in the jurisdiction where Roach resided, Lafayette City Court. The lower court denied the motion for confirmation for want of jurisdiction in that the confirmation motion was filed in an improper venue under a Louisiana statute requiring an award to be confirmed in the parish where the award was made.

On appeal, Chase argued that the lower court erred in applying Louisiana law. The Court noted that Federal arbitration law governs contracts for arbitration involving interstate commerce. Under the Uniform Arbitration Act and the Revised Uniform Arbitration Act, confirmation can be made in the county where the award was made, the county where the debtor resides or signed the contract, or where designated in the agreement.

Further, the Fair Debt Collection Practices Act requires that the confirmation be filed where the contract was signed or the debtor resides. Thus, the Court determined that the lower court erred in refusing to confirm the arbitration award based on lack of jurisdiction and improper venue.

The Court then determined that the award should be confirmed. The Court noted that unless the party attacking the award has established grounds for vacating, modifying, or correcting the award, then the award must be confirmed.

In this case, Roach raised no issues challenging the arbitration award. The Court reversed the lower court's decision and confirmed the arbitration award in favor of Chase.