Nissan Motor Acceptance Company LLC v. Fludd

Background

Nissan Motor Acceptance Company LLC filed a motion under Section 9 of the Federal Arbitration Act to confirm an arbitration award. Nissan submitted the arbitration award and the demand for arbitration with its motion. Jovan Fludd did not present a specific argument opposing confirmation. Instead, he objected to the court’s exercise of jurisdiction over him.

Legal standard

The court stated that arbitration decisions receive substantial deference. Confirming an arbitration award is generally a summary process that turns the award into a court judgment. Under the Federal Arbitration Act, a court must confirm the award unless a legally recognized ground requires the award to be vacated, modified, or corrected.

The statute identifies limited grounds for vacating an award, including corruption, fraud, undue means, arbitrator bias or corruption, serious arbitrator misconduct, or an arbitrator exceeding the arbitrator’s authority. The court also noted that an award may be vacated when it shows disregard for the parties’ agreement.

Decision

The court found that none of those circumstances applied. It determined that Nissan had sufficiently supported its motion and had shown that no material fact was in dispute. Because Fludd had not made a specific argument opposing the motion, the court granted Nissan’s motion as required by the Federal Arbitration Act.

Judge Naomi Reice Buchwald directed the Clerk of Court to terminate the motion at ECF No. 8 and close the case.