Perspectives: 'Partial Final' Does Not Mean Final

[Editor's note: Guest editor Brendan Gooley is a litigator who focuses on employment discrimination, education, and insurance matters. He joined Carlton Fields after clerking for the United States Court of Appeals for the Second Circuit and the Connecticut Supreme Court.]

Don’t try to confirm an arbitration award when there is still arbitration work to be done. Relying on Seventh Circuit precedent, the Northern District of Illinois concluded that it lacked subject-matter jurisdiction to confirm an arbitration award because the arbitrators’ work was incomplete and the arbitration hearing wasn’t finished.

FCE Benefit Administrators Inc., a third-party benefits administrator, agreed to administer …