On December 5, 2025, the Supreme Court granted certiorari in Jules v. Andre Balazs Properties, No. 25-83, to decide an important jurisdictional question in the enforcement of domestic arbitration awards: whether a federal court that had jurisdiction over a claim when a lawsuit was initially filed, but then sent to arbitration, can later confirm or overturn an arbitration award even if there is no other basis for federal-court jurisdiction at that later stage. The Supreme Court’s decision in Jules will shape enforcement procedures and strategies for domestic arbitrations going forward.
Background of the Dispute
Adrian Jules, a former employee of the Chateau Marmont hotel in Los Angeles, sued hotelier André Balazs and related companies in federal court in New York. Jules claimed that his termination violated federal and California laws. Because Jules’s employment contract contained an arbitration clause, the court stayed the lawsuit under Section 3 of the Federal Arbitration Act (FAA) and sent it to arbitration. After the arbitrator ruled against Jules, the case returned to federal court, where defendants asked the court to confirm the arbitration award under Section 9 of the FAA. Jules objected to the jurisdiction of the federal district court.
In September 2023, the federal district court confirmed the award. The court held that it still had jurisdiction because the case was properly in federal court when Jules first filed it, as Jules’s complaint included federal law claims. The judge also reasoned that, because the case had only been stayed pending arbitration, the court retained the authority to decide the post-arbitration motions.
Jules appealed, arguing that, under Badgerow v. Walters, 596 U.S. 1 (2022), the district court should not have relied on the substance of the original dispute to justify jurisdiction. In Badgerow, the Supreme Court held that the FAA does not itself provide the federal courts with jurisdiction over an application to confirm an arbitration award under Section 9, or an application to vacate an arbitration award under Section 10. Nor can a federal court “look through” the application to the merits of the underlying dispute to find a basis for federal jurisdiction. Instead, a federal court can exercise jurisdiction over the application only where the face of the application demonstrates some independent basis for federal jurisdiction (such as diversity jurisdiction).
In April 2025, the Second Circuit upheld the district court’s decision. It acknowledged that the FAA does not itself grant jurisdiction and that Jules’s motion to vacate did not show any independent federal basis. The Second Circuit held that the district court properly exercised jurisdiction because “a court which orders arbitration retains jurisdiction to determine any subsequent application involving the same agreement to arbitrate, including a motion to confirm the arbitration award”[i]—an issue that the Supreme Court did not address in Badgerow.[ii] In other words, the Second Circuit treated the original lawsuit and the post-arbitration enforcement as one continuous case—an approach known as the “jurisdictional anchor.” Jules petitioned the Supreme Court for review.[iii]
The Circuit Split on Post-Arbitration Jurisdiction
Jules raises a technical but important question at the intersection of arbitration law and federal jurisdiction. Under the FAA, a party who wins in arbitration can ask a court to confirm the award (Section 9), while the losing party can ask to vacate it (Sections 10 and 11). But the FAA does not itself give federal courts the authority to enforce domestic arbitration awards.[iv] That authority must come from another source, such as federal-question jurisdiction or diversity jurisdiction. Accordingly, many enforcement actions are filed in state court, not federal court.
In Badgerow, the Supreme Court held that courts cannot create jurisdiction to enforce a domestic arbitration award by looking at the substance of the dispute underlying the arbitration award, such as whether it involved a federal claim. But the Supreme Court did not answer a key question: If the arbitration stems from a lawsuit that was properly filed in federal court, can the same court later enforce the award as part of the original case? Or does the party need to file a new lawsuit with its own jurisdictional basis?
Federal appeals courts are split. Most circuits hold that if a court had jurisdiction and stayed the case for arbitration, it can resume the case afterward to confirm or vacate the award without needing a new jurisdictional hook.[v] But the Fourth Circuit had disagreed, holding that applications to confirm or vacate an arbitration award are separate proceedings that require their own independent basis for federal jurisdiction.[vi] As a result, parties in similar situations could face different outcomes depending on where they file their application. For example, in New York (Second Circuit), a party who started in federal court could stay there to confirm the award. But in Maryland or Virginia (Fourth Circuit), the same party might be forced to go to state court for enforcement. This inconsistency raises concerns about forum-shopping and strategic maneuvering.
Implications
The Supreme Court’s decision in Jules may shape how domestic arbitration awards are enforced across the country. If the Court upholds the “jurisdictional anchor” theory, lower courts would treat enforcement as part of the original case. Parties could have certainty that commencing an action in federal court would mean staying there through the end of the dispute. If the Court rejects that theory, more post-arbitration enforcement actions are likely to end up in state courts. Parties would thus need to plan for the possibility that even if they file a claim in federal court, they may have to switch to state court to enforce an arbitration award.
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[i] Jules v. Andre Balazs Props., No. 23-1253, 2025 WL 1201914, at *2 (2d Cir. Apr. 25, 2025), cert. granted sub nom. Jules v. Andre Balazs Prop., No. 25-83, 2025 WL 3493153 (U.S. Dec. 5, 2025) (citing Smiga v. Dean Witter Reynolds, Inc., 766 F.2d 698, 705 (2d Cir. 1985)).
[ii] Id.
[iii] Jules v. Andre Balazs Prop., No. 25-83, 2025 WL 3493153 (U.S. Dec. 5, 2025).
[iv] Hall St. Assocs., L.L.C. v. Mattel, Inc., 552 U.S. 576, 581-82 (2008); Moses H. Cone Mem’l Hosp. v. Mercury Constr. Corp., 460 U.S. 1, 25 n.32 (1983); Vaden v. Discover Bank, 556 U.S. 49, 59 (2009); Westmoreland Cap. Corp. v. Findlay, 100 F.3d 263, 267 (2d Cir. 1996); Perpetual Sec., Inc. v. Tang, 290 F.3d 132, 136 (2d Cir. 2002).
[v] See e.g., Smiga, 766 F.2d at 705; George v. Rushmore Serv. Ctr., LLC, 114 F.4th 226 (3d Cir. 2024); Kinsella v. Baker Hughes Oilfields Operations, LLC, 66 F.4th 1099 (7th Cir. 2023); Rodgers v. United Servs. Auto. Ass’n, No. 21-50606, 2022 WL 2610234 (5th Cir. 2022); Smart v. Sunshine Potato Flakes, L.L.C., 307 F.3d 684 (8th Cir. 2002); Dodson Int'l Parts, Inc. v. Williams Int'l Co. LLC, 12 F.4th 1212 (10th Cir. 2021); PTA-FLA, Inc. v. ZTE USA, Inc., 844 F.3d 1299 (11th Cir. 2016).
[vi] SmartSky Networks, LLC v. DAG Wireless, Ltd., 93 F.4th 175, 177–78, 183–84 (4th Cir. 2024).
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