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A federal district court in Pennsylvania has dismissed without prejudice a motion for default judgment seeking confirmation of an arbitration award. The Court not only found a lack of federal jurisdiction, but also that the use of "default judgment" was an improper mechanism to achieve confirmation.
In Chase Bank USA, N.A. v. Hillis, Civil Action No. 07-273, 2007 WL 1276905 (W.D. Pa. Apr. 30, 2007), Chase won an arbitration award against Hillis, and sought to have it confirmed in Federal Court.
Though Chase cited the Federal Arbitration Act to establish jurisdiction, the Court noted that it is well-established that a petitioner seeking to confirm an arbitration award "must establish an independent basis for federal jurisdiction."
Even if the Court had found jurisdiction, it noted that a motion for default judgment was a "generally inappropriate" means to confirm or vacate an award. Rather, a petition seeking confirmation should be accompanied by a record of the proceedings, and will be treated by the courts as a motion for summary judgment.
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