Teamsters Local 177 v. UPS

In 2015, after the Teamsters filed a demand for arbitration, the Arbitrator sustained the Teamsters’ grievances and ordered UPS to cease and desist. In 2018, UPS violated the Arbitrator’s order. The Union ultimately obtained a monetary settlement for the violations by UPS. Thereafter, the Teamsters moved for confirmation of the order under Section 9 of the FAA. The District Court held that confirmation is not proper without an active controversy. The Teamsters appealed, and the Third Circuit Court reversed.

The Court 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.”