Puerto Rico Telephone Company, Inc. v. Worldnet Telecommunications, LLC
Split Score
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Case Summary
Disposition
Vacated
Puerto Rico Telephone Company asked the First Circuit to confirm an arbitration award under § 9 of the Federal Arbitration Act. After the district court dismissed for lack of standing, the Supreme Court decided Badgerow v. Walters, which held that federal courts generally lack subject-matter jurisdiction over § 9 and § 10 confirmation or vacatur requests unless another independent basis exists. Applying Badgerow, the First Circuit vacated the district-court judgment and remanded with instructions to dismiss without prejudice for lack of subject-matter jurisdiction.
Circuit Split Identified
Legal Issue
Whether federal courts may exercise subject-matter jurisdiction over applications to confirm or vacate arbitration awards under FAA §§ 9 and 10 by using the "look-through" approach to the underlying dispute.
Circuit Positions
Apply Vaden-style look-through test and exercise federal-question jurisdiction over § 9/§ 10 applications.
No look-through; jurisdiction must appear on the face of the § 9/§ 10 application itself.
Conflict Summary
Several circuits (including the First) applied the Vaden ‘look-through’ approach, finding jurisdiction whenever the underlying arbitration dispute presented a federal question, while other circuits limited jurisdiction to what appears on the face of the § 9 or § 10 application and therefore usually found no federal jurisdiction absent diversity or another independent ground.