As discussed in the following article, the U.S. Supreme Court has recently resolved a split between the circuits by holding in Badgerow v. Walters, et al., that in order for a federal court to review an arbitrator's award under the Federal Arbitration Act, there must be an independent basis for federal jurisdiction. Therefore, some petitions previously brought to federal court to vacate, modify or confirm an arbitration award must now be brought in state court.
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