The Delaware Supreme Court, in Gulf LNG Energy, LLC, et al. v. ENI USA Gas Marketing, LLC, No. 22, 2020, opinion (Del. Nov. 17, 2020), found claims asserted in a second arbitration constituted an impermissible collateral attack on an award in a first arbitration that, under the Federal Arbitration Act, could only be asserted in a court proceeding to review, vacate, or modify the first arbitration award.

Morris James discusses the decision in Delaware Supreme Court Finds that Court of Chancery Had Jurisdiction To Enjoin a Collateral Attack on a Prior Arbitration Award Under the Federal Arbitration Act.