Evans Cabinet Corp. v. Kitchen International
Citation and Court
593 F.3d 135 (1st Cir. 2010)
Facts
Evans Cabinet Corp. and Kitchen International had an ongoing commercial relationship. Following a dispute, Kitchen International obtained an arbitral award in Canada. It then sought enforcement of that award in U.S. federal court under the New York Convention.
Issue
Whether a foreign arbitral award that is “non-domestic” (rendered abroad) is subject to enforcement in U.S. courts under the New York Convention and Chapter 2 of the Federal Arbitration Act.
Holding
The court enforced the Canadian arbitral award, applying the New York Convention framework; defenses to enforcement are narrow and the strong federal policy favoring arbitration counsels in favor of recognition.
Rule / Doctrine
Under the New York Convention (implemented through FAA Chapter 2), U.S. courts must recognize and enforce foreign arbitral awards unless a defendant establishes one of the Convention’s limited grounds for refusal, such as lack of due process, non-arbitrability, or violation of public policy.
Significance
Evans Cabinet illustrates the high threshold for resisting enforcement of foreign arbitral awards in the United States under the New York Convention and the strong judicial presumption in favor of enforcement.