No Jurisdiction in New York to Set Aside a Tennessee Arbitration

Morgan Keegan & Co., Inc. v Rote,

115 A.D.3d 516, 982 N.Y.S.2d 448 [1st Dept., 2014]
Petitioner sought to set aside an arbitration award, and the threshold question was whether or not the petition could be heard in New York.
The arbitration agreement specified that the hearing was to be held in Memphis, Tennessee, in accordance with FINRA rules. Several days’ worth of the hearings were in fact held in New York, for the convenience of the arbitrators. The case had no other connection to New York.
These facts did not suffice as a basis for the assertion of personal jurisdiction in New York, and the petitioner’s petition to set aside the arbitration award was properly denied.