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Halliburton Energy Services, Inc. v. Donald Stennett
2:20-cv-07488
C.D. Cal.
Mar 3, 2021
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Background

  • 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)
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Case Details

Case Name: Halliburton Energy Services, Inc. v. Donald Stennett
Court Name: District Court, C.D. California
Date Published: Mar 3, 2021
Citation: 2:20-cv-07488
Docket Number: 2:20-cv-07488
Court Abbreviation: C.D. Cal.