Second Circuit Finds That Arbitrators Should Decide Claim Preclusion of Confirmed Award

In its recent decision Citigroup, Inc. v. Abu Dhabi Investment Authority, No. 13-4825-cv, 2015 WL 161745 (2d Cir. Jan. 14, 2015), the U.S. Court of Appeals for the Second Circuit found that the question of whether a federal judgment confirming a prior arbitral award precludes subsequent arbitration of claims, is ordinarily for the arbitrators to decide, not the federal courts.

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