Los Angeles County Pioneer Society v. Historical Society

How later courts describe this case

• “[a] party may, therefore, apply to the court for an order confirming the award, but is not limited to such remedy. Before the enactment of the United States Arbitration Act, an action at law on the award was the proper method of enforcing it.”
• “The language of [Section 9] . is not mandatory, but permissive ... Enforcement of the award in this case is not barred by the one-year limitation contained in Section 9 of the Act, which provides for the summary remedy of confirmation of the award by the court”