In Teamsters Local 177 v. UPS, the 3rd Circuit held that, under the FAA, a party’s injuries are only fully remedied by the entry of a confirmation order. The dispute the parties went to arbitration to resolve is “live” until the arbitration award is confirmed and the parties have an enforceable judgment in hand. Thus, “the confirmation of an arbitration award is a summary proceeding that merely makes what is already a final arbitration award a judgment of the court.”
