Under Ohio law, an application to confirm an arbitration award need only include the parties' written arbitration agreement, not a signed agreement, according to the Ohio Court of Appeals.

In Chase Manhattan Bank USA v. Myers, No. 07CA48, 2008 WL 629995 (Ohio Ct. App. Feb. 28, 2008), Chase filed a claim against Myers for an unpaid credit card balance in accordance with the parties' arbitration agreement. The arbitrator issued an award in favor of Chase.

Chase filed a motion to confirm and enforce the award with the trial court. The trial court granted Chase's motion.

On appeal, Myers argued that Chase had failed to comply with Ohio arbitration law by attaching an unsigned copy of the parties' arbitration agreement to its application for confirmation. The Court, however, restated the well-settled rule that an arbitration agreement must be written, "but it is not required that the agreement be signed by the parties." See Ohio Rev. Code § 2711.14(A) (requiring that the parties' agreement be filed upon application to confirm, but making no mention of any signature requirement).

Since Myers had attacked the propriety of Chase's application, instead of properly filing a motion to vacate, modify, or correct the disputed award within the requisite time period, the Court could not disturb the trial court's confirmation absent a material mistake or extensive impropriety during arbitration. Finding neither, the Court affirmed the order confirming the award.