US Supreme Court Rule That One Cannot Look To Underlying Dispute To Establish Jurisdiction Compels Result.

        "Vacating the district court’s order granting Tesla, Inc. and Elon Musk’s petition to confirm an arbitration award, the panel held that the district court lacked subject matter jurisdiction to confirm the award pursuant to Badgerow v. Walters, 596 U.S. 1 (2022), which prohibits looking past the face of a petition under 9 U.S.C. § 9 to establish jurisdiction." Tesla Motors Inc.; Elon Musk v. Cristina Balan, No. 23-16045 (9th Cir. 4/14/25) (VanDyke, Collins, Mendoza).

        Tesla and Musk sought to confirm a zero dollar arbitration award resulting from a defamation claim brought by Balan, an automotive design engineer who had been a Tesla employee. The district court affirmed the arbitration award.

        However, as the Court of Appeals opinion explains, the district court lacked diversity jurisdiction to confirm the award, because on its face the petition to confirm stated the award was zero, that is, below the $75,000 threshold necessary to establish diversity jurisdiction. And under Badgerow v. Walters, a party relying on  9 U.S.C. § 9 to confirm an award cannot make the court look beyond the petition to the nature of the underlying dispute.

        Tesla argued that the district court coulda shoulda issued a stay, in which case it would have retained federal jurisdiction. Maybe the district court shoulda, but the matter was dismissed without objection. The district court could not have issued a stay after dismissing the case.

        So the order confirming the award was vacated, and the case was remanded to the district court with instructions to dismiss for lack of jurisdiction.