DeLucca v. Hayfin Capital Management LLC
- Paul Engelmayer
- 1:24-cv-00494
- U.S. District Court · Southern District of New York
- 2
In DeLucca v. Hayfin, Judge Engelmayer ordered Joyce DeLucca to explain the federal court’s jurisdiction before deciding whether the case can proceed.
Joyce DeLucca and Hayfin Capital Management LLC; the order requires DeLucca to address federal jurisdiction before the court decides whether the case may proceed.
What happened
In DeLucca v. Hayfin Capital Management LLC, Joyce DeLucca asked the court to review and vacate an arbitration award under the Federal Arbitration Act. Her filings identified the Act as the only basis for federal jurisdiction.
The court explained that the Federal Arbitration Act permits courts to review arbitration awards but does not itself give federal courts jurisdiction. It ordered DeLucca to file a letter explaining any independent basis for jurisdiction by February 9, 2024. Hayfin Capital Management LLC may oppose that letter by February 14, 2024.
The court has not yet decided whether it can hear the case or whether the action must be dismissed for lack of jurisdiction. Judge Paul A. Engelmayer also directed DeLucca to serve the order on Hayfin Capital Management LLC.
The detailed version
- DeLucca v. Hayfin Capital Management LLC · No. 1:24-cv-00494
- Paul Engelmayer
- Jan. 31, 2024
Background
Joyce DeLucca filed a petition and motion asking the court to vacate an arbitration award under the Federal Arbitration Act, a federal statute governing arbitration. Her filings cited only that statute as the basis for the court’s subject-matter jurisdiction, meaning the court’s power to hear the dispute.
Jurisdictional issue
The court explained that the Federal Arbitration Act authorizes a federal district court to review an arbitration award but does not itself create federal subject-matter jurisdiction. The court therefore must identify an independent jurisdictional basis before it can consider DeLucca’s petition.
Order
The court ordered DeLucca to file a letter by February 9, 2024, explaining what basis, if any, supports federal jurisdiction. Hayfin Capital Management LLC may file an opposition letter by February 14, 2024, and the court stated that no replies were invited at that time. The court will later determine whether it may hear the case or whether the action must be dismissed for lack of jurisdiction. The order also directed DeLucca to serve a copy on Hayfin Capital Management LLC. Judge Paul A. Engelmayer did not decide the petition or motion to vacate in this order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.