Tesla Motors, Inc. v. Cristina Balan, 134 F.4th 558

Cristina Balan, a former Tesla automotive engineer, alleged that Tesla and Elon Musk defamed her in response to a 2017 Huffington Post article.
Balan filed a federal lawsuit in 2019 against Tesla in the Western District of Washington for defamation.
The court compelled the claim to arbitration based on Balan’s employment agreement, later ordering the case dismissed after appeals.
In arbitration, Balan amended her claim to add Musk based on additional purportedly defamatory statements.
The arbitrator dismissed both claims as time-barred under California law and issued a zero-dollar award in favor of Tesla and Musk.
Tesla and Musk petitioned the Northern District of California to confirm the arbitration award; the district court granted their petition, and Balan appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
District court jurisdiction under the FAA to confirm arbitration award	The district court lacked subject matter jurisdiction to confirm the award per Badgerow; jurisdictional facts must be on the face of the petition.	Jurisdiction exists under diversity or Section 3 of the FAA; the court should have stayed, not dismissed, allowing confirmation.	No subject matter jurisdiction: facts must be on the face; zero-dollar award fails the amount-in-controversy requirement.
Application of Badgerow v. Walters	Badgerow prohibits “look-through” jurisdiction for Section 9 petitions.	Argued Badgerow inapplicable because case should have been stayed.	Badgerow controls; "look-through" is not permitted under Section 9.
Whether the dismissal or stay of the original suit matters	N/A (focus on jurisdiction under Section 9)	The original suit should have been stayed per Spizzirri, allowing return to court.	The initial case was dismissed, not stayed; no jurisdiction follows.
Amount-in-controversy requirement for diversity	The petition on its face did not show $75,000+ due to a zero-dollar award.	Did not directly contest facial deficiency, focused on alternative grounds.	Petition failed to meet $75,000 requirement; no diversity jurisdiction.

Badgerow v. Walters, 596 U.S. 1 (2022) (FAA Section 9 and 10 petitions require jurisdictional facts on the face of the application; no "look-through" permitted)
Kokkonen v. Guardian Life Ins. Co. of America, 511 U.S. 375 (1994) (federal courts are courts of limited jurisdiction)
Hall St. Assocs., L.L.C. v. Mattel, Inc., 552 U.S. 576 (2008) (FAA does not create independent federal jurisdiction)
Smith v. Spizzirri, 601 U.S. 472 (2024) (courts must stay, not dismiss, cases under Section 3 of the FAA when arbitration is compelled)