The Tennessee Supreme Court today held that Tennessee courts do not have jurisdiction to confirm arbitration awards when the parties agreed that arbitration would occur in another state.
Berkeley Research Group and Southern Advanced Materials entered into a contract in which they agreed that any dispute arising from the contract would be resolved by arbitration in Philadelphia, Pennsylvania. When a dispute later arose, the parties conducted arbitration over Zoom, but the arbitrator was located in Philadelphia. The arbitrator ruled in favor of Berkeley Research Group, which then filed a case in Shelby County Chancery Court to enter judgment on, or confirm, the arbitration award.
The Tennessee Supreme Court held that under the Uniform Arbitration Act, Tennessee courts do not have subject matter jurisdiction to confirm an out-of-state arbitration award where the parties agreed that arbitration would take place in another state. Because the parties agreed that arbitration would take place in Pennsylvania, the court did not have jurisdiction to confirm the arbitration award.
To read the Supreme Court’s opinion in Berkeley Research Group, LLC v. Southern Advanced Materials, LLC, authored by Justice Dwight E. Tarwater, visit the opinions section of TNCourts.gov.