Gulf LNG Energy v. ENI USA Gas Marketing

Summary

The court held that the Court of Chancery had jurisdiction to enjoin a second arbitration that was a collateral attack on a prior arbitration award, notwithstanding the parties’ broad arbitration clause. It further held that all claims in the second arbitration sought either to challenge alleged irregularities in the first arbitration or to recoup amounts awarded there, making them impermissible attempts to bypass the Federal Arbitration Act’s exclusive and time-limited review procedures. The judgment was affirmed in part, reversed in part, and remanded for expansion of the injunction.