Halliburton Energy Services, Inc. v. Donald Stennett
2:20-cv-07488
C.D. Cal.Mar 3, 2021Background
- On February 25, 2020, a JAMS arbitrator issued a Final Arbitration Award in favor of Halliburton, finding that Stennett had validly released all claims against his former employer.
- By stipulation dated July 21, 2020, Stennett and Halliburton agreed to have the Final Arbitration Award confirmed by a court and expressly agreed there were no grounds to vacate the award.
- Halliburton filed a Consent Petition to Confirm Final Arbitration Award and for Entry of Judgment in federal district court.
- The parties’ arbitration agreement incorporated the Federal Arbitration Act (FAA) and expressly contemplated court confirmation of awards.
- The court noted that judicial review of arbitration awards under the FAA is extremely limited and found no statutory grounds to vacate, modify, or correct the award.
- The court granted Halliburton’s Consent Petition, confirmed the Final Arbitration Award, and ordered Halliburton to submit a Proposed Judgment within 14 days.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court must confirm the Final Arbitration Award | Halliburton: FAA requires confirmation; Stennett consented and agreed there are no grounds to vacate | Stennett: (did not oppose confirmation; stipulated there are no grounds to vacate) | Court: Must grant confirmation; no basis under FAA to vacate, modify, or correct the award |
Key Cases Cited
- Hall St. Assocs., LLC v. Mattel, 552 U.S. 576 (U.S. 2008) (FAA requires courts to confirm awards unless statutory exceptions apply)
- Kyocera Corp. v. Prudential-Bache Trade Servs., Inc., 341 F.3d 987 (9th Cir. 2003) (federal review of arbitration awards is extremely limited)
- Bosack v. Soward, 586 F.3d 1096 (9th Cir. 2009) (erroneous legal conclusions or unsubstantiated factual findings do not justify vacatur under the FAA)
- Cent. Mont. Rail v. BNSF Ry. Co., [citation="422 F. App'x 636"] (9th Cir. 2011) (court must confirm arbitration award unless vacatur, modification, or correction is warranted)
