Pinnavaia v. National Arbitration Forum, Inc.

Matthew Pinnavaia appeals from the final judgment entered in the District Court for the District of Minnesota dismissing his civil complaint. For reversal Pinnavaia argues, inter alia, the district court erred in determining that he did not state a claim under the Federal Arbitration Act, 9 U.S.C. § 10. For the reasons discussed below, we modify the judgment of the district court and affirm as modified.

In keeping with the other circuits that have addressed the issue, we hold that 9 U.S.C. § 10 does not provide an independent jurisdictional basis for filing suit in federal court. See Smith v.…