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Keywords

arbitrationhearingburden of proofwillarbitratorappellant
arbitration

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Kolel Beth Yechiel Mechil of Tartikov, Inc. v. YLL Irrevocable Trust, 729 F.3d 99

Facts

Issue

Whether the arbitration award should be vacated due to alleged evident partiality or corruption of the arbitrator.

Whether there was 'abundantly clear' evidence of corruption to vacate the arbitration award under the FAA.

Rule

Under the Federal Arbitration Act, a court's role in reviewing an arbitration award is limited, and the burden of proof to vacate an award is high. A party seeking vacatur must demonstrate evident partiality or corruption by clear and convincing evidence. The court will enforce the award if there is a barely colorable justification for the outcome. The decision to deny an evidentiary hearing is reviewed for abuse of discretion.

Analysis

The court found that Appellants did not provide sufficient evidence to demonstrate that the arbitrator was biased or corrupt. The allegations made by Appellants were deemed too speculative and did not meet the high burden of proof required to vacate the arbitration award. The court emphasized that the arbitrator's actions did not rise to the level of evident partiality, and the arbitration process was not fundamentally unfair despite the limited number of witnesses heard.

Conclusion

The court affirmed the district court's decision to confirm the arbitration award, concluding that Appellants failed to meet the burden of proof necessary to vacate the award.

Given that YLL has failed to show any 'abundantly clear' evidence of corruption, we affirm the district court's decision.

Who won?

Kolel Beth Yechiel Mechil of Tartikov, Inc. prevailed in this case as the court confirmed the arbitration award in its favor. The court found that the Appellants did not provide adequate evidence to support their claims of bias or corruption against the arbitrator. The decision reinforced the principle that arbitration awards are given great deference under the Federal Arbitration Act, and the burden of proof to vacate such awards is very high.

Kolel Beth Yechiel Mechil of Tartikov, Inc. prevailed in this case as the court confirmed the arbitration award in its favor.

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