Reineri v. International Business Machines Corporation

Background

Robert Reineri filed a petition under Sections 9 and 13 of the Federal Arbitration Act seeking confirmation of an arbitration award issued in his favor against International Business Machines Corporation (IBM). He also asked the court to unseal the award. The dispute arose from an agreement under which Reineri released certain claims, retained the ability to bring an age-discrimination claim, and agreed to pursue such a claim through private arbitration. The arbitrator issued the award on October 20, 2021, and IBM paid the amount awarded on November 1, 2021.

Jurisdiction

The court explained that it could act only if it had subject-matter jurisdiction, meaning legal authority to hear the dispute. It rejected IBM's argument that payment of the award eliminated the required live dispute. Under Second Circuit precedent, paying an arbitration award does not prevent a court from confirming it.

The court nevertheless found that Reineri had not established federal jurisdiction. The Federal Arbitration Act authorizes a party to seek confirmation but does not itself create federal-question jurisdiction. The underlying age-discrimination dispute involved federal law, but the present petition concerned confirmation of an arbitration award, and the court could not examine the underlying dispute to create jurisdiction.

The court also found that the petition did not adequately establish diversity jurisdiction. Reineri alleged that he was a resident of Tennessee and that IBM was a New York corporation with its principal place of business in New York. But an individual's residence does not establish citizenship or domicile for diversity purposes, and the petition also did not allege facts showing that the amount in controversy exceeded $75,000.

Amendment and Sealing

The court determined that the defective jurisdictional allegations might be correctable if diversity jurisdiction actually existed when the case began. It therefore gave Reineri an opportunity to submit a proposed amended petition and a motion for leave to amend within 14 days of the order.

Because jurisdiction remained unresolved, the court could not reach the merits of Reineri's request to confirm the award or his request to unseal it. The court separately concluded that, at that stage, the sealed award was not a judicial document because its contents were irrelevant to the jurisdictional analysis. It therefore did not continue with the analysis governing public access to judicial documents.

Conclusion

The court did not confirm the arbitration award, did not unseal it, and did not dismiss the case. Instead, because Reineri had not met his burden of establishing subject-matter jurisdiction, Judge Moses directed him to submit any proposed amended petition and a motion for leave to amend within 14 days.