Berkeley Research Group, LLC v. Southern Advanced Materials, LLC

Summary

The Tennessee Supreme Court held that Tennessee courts lack subject matter jurisdiction to confirm an arbitration award when the parties’ agreement provides that arbitration will occur exclusively in another state. Because the agreement required arbitration in Pennsylvania, the Shelby County Chancery Court lacked jurisdiction to confirm the award. The court vacated the lower-court judgments and dismissed the petition to confirm the award.

Holdings

1. Under Tennessee's Uniform Arbitration Act, Tennessee courts have subject matter jurisdiction to confirm an arbitration award only when the arbitration agreement provides for arbitration in Tennessee. Because the parties' agreement required arbitration exclusively in Pennsylvania, the Shelby County Chancery Court lacked subject matter jurisdiction to confirm the award.
2. The Court did not decide whether Southern had sufficient contacts with Tennessee or consented to personal jurisdiction by contract because the lack of subject matter jurisdiction was dispositive.

Questions Presented

1. Whether Tennessee courts have subject matter jurisdiction under the Uniform Arbitration Act to confirm an arbitration award when the parties' agreement requires arbitration to occur exclusively in another state.
2. Whether the court had personal jurisdiction over Southern based on the arbitration agreement's provision that judgment on an award may be entered by any state or federal court having jurisdiction.

Disposition

vacated