Brown v. JPMorgan Chase Bank, N.A
- Subramanian
- 1:25-cv-05633
- U.S. District Court · Southern District of New York
- 1
In Brown v. JPMorgan Chase, Judge Subramanian ordered Meghan Brown to explain federal jurisdiction in her petition to confirm an arbitration award.
Meghan Brown must explain the basis for federal jurisdiction; the respondents are JPMorgan Chase Bank, N.A. and JP Morgan Securities LLC.
What happened
Meghan Brown asked the Southern District of New York to confirm an arbitration award against JPMorgan Chase Bank, N.A. and JP Morgan Securities LLC. She told the court that the respondents’ lawyer said they would not object, but the respondents had not appeared.
Brown identified the Federal Arbitration Act as the basis for federal-question jurisdiction. The court explained that the Act by itself does not give federal courts jurisdiction, so another legal basis is required.
Judge Arun Subramanian ordered Brown to send a letter by August 1, 2025, explaining the basis for jurisdiction. If she relies on the parties’ diversity of citizenship, she must identify each party’s citizenship.
The detailed version
- Brown v. JPMorgan Chase Bank, N.A · No. 1:25-cv-05633
- Subramanian
- July 28, 2025
Background
Meghan Brown filed a petition asking the court to confirm an arbitration award. She later told the court that counsel for the respondents had indicated that they did not intend to object to or contest confirmation of the award. The court noted, however, that the respondents had not appeared.
Jurisdiction issue
Brown stated that the court had federal-question jurisdiction because the matter arose under the Federal Arbitration Act (FAA). The court explained that the FAA itself does not create subject-matter jurisdiction, meaning it does not by itself authorize a federal court to decide the matter. The court said Brown therefore had to identify an independent basis for federal jurisdiction.
Order
Judge Arun Subramanian directed Brown to submit a letter by August 1, 2025, explaining the basis for jurisdiction. The order specifically required Brown to identify the citizenship of each party if she relied on diversity of citizenship. The opinion does not state that the court confirmed or refused to confirm the arbitration award.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.