Seventh Circuit Analyzes Its Jurisdiction Under The Panama Convention

International arbitration can be tricky, and it's not often that the Seventh Circuit has an opportunity to analyze the grounds for its jurisdiction in this area. That makes the court's recent decision in Pine Top Receivables of Illinois v. Banco de Seguros del Estado, Nos. 13-1364 & 13-2331 (7th Cir. Nov. 7, 2014), a unique case worth remembering.

The case began when Pine Top sought to compel arbitration by filing a complaint in the Northern District of Illinois against Banco de Seguros del Estado, an entity wholly owned by Uruguay. The dispute concerned approximately $2.3 million that Pine Top claimed Banco owed under reinsurance contracts. The district court denied the motion to compel, and Pine Top took an interlocutory appeal under 9 U.S.C. § 16, as it was authorized to do under that part of the Federal Arbitration Act. Or was it?