In Tesla Motors, Inc. v. Balan, No. 22-16623, 2025 WL 1096931, at *2-3 (9th Cir. Apr. 14, 2025)., the Ninth Circuit held that a district court did not have jurisdiction to confirm a zero-dollar award.
As a threshold matter, it is uncontested by the parties that federal question jurisdiction does not apply, because the Federal Arbitration Act (“FAA”) “bestow[s] no federal jurisdiction but rather requir[es]” that parties seeking relief under the FAA establish “an independent jurisdictional basis” for a federal court’s jurisdiction. Hall St. Assocs., L.L.C. v. Mattel, Inc., 552 U.S. 576, 582, 128 S.Ct. 1396, 170 L.Ed.2d 254 (2008).
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[A]n arbitration award “is no more than a contractual resolution of the parties’ dispute—a way of settling legal claims.” Badgerow, 596 U.S. at 9, 142 S.Ct. 1310. Thus, for federal question jurisdiction to attach in a suit brought under the FAA, the complaint must include an averment under federal law other than Sections 9 or 10 of the FAA. See Badgerow, 596 U.S. at 7–9, 142 S.Ct. 1310.
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Because a “look through” approach is prohibited under Badgerow, the facts establishing a jurisdictional basis must be present on the face of the application or petition to confirm an arbitration award. Seeid. at 16–17, 142 S.Ct. 1310. Put differently, facts establishing that the amount in controversy exceeds $75,000 must be present on the face of a Section 9 petition to confirm an arbitration award before a district court can assert diversity jurisdiction over the action. Id. at 9, 142 S.Ct. 1310; see alsoSky-Med, Inc. v. Fed. Aviation Admin., 965 F.3d 960, 965 (9th Cir. 2020).
Here, the award for zero dollars could not meet the $75,000 threshold for diversity jurisdiction.
