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Keywords

arbitrationinjunctionappealarbitrator

contractarbitrationtrialarbitrator

Related Cases

Lindland v. U.S. Wrestling Ass’n, Inc., 227 F.3d 1000

Facts

Amateur wrestler Matt Lindland sought to compel the United States Olympic Committee (USOC) to nominate him for the Olympic team after winning a rematch against Keith Sieracki, who had initially been nominated. Lindland had previously won an arbitration award ordering the rematch, but USA Wrestling defied this by nominating Sieracki instead. The dispute escalated to the federal courts, where the district court ordered the USOC to comply with the arbitration award and nominate Lindland. The case involved multiple appeals and arbitration awards, leading to a complex legal battle over the nomination process.

Issue

Whether the district court's order directing the USOC to nominate Lindland was valid and whether the separate arbitration award obtained by Sieracki could be confirmed.

Rule

The Ted Stevens Olympic and Amateur Sports Act allows for arbitration of disputes involving athlete nominations to the Olympic team, but does not permit arbitration regarding the propriety of another arbitrator's decision. An arbitrator must act within the powers granted by the rules governing arbitration, and any award made outside those powers is invalid.

Analysis

The court found that the dispute was not moot despite the IOC's substitution of Lindland for Sieracki, as the underlying issues regarding the arbitration awards remained unresolved. The court determined that the arbitrator exceeded his authority by attempting to redetermine the merits of a claim already decided, thus invalidating the separate arbitration award sought by Sieracki. The USOC was bound by the injunction requiring it to nominate Lindland, as it was in active concert with USA Wrestling, which had received notice of the court's order.

Arbitrators are bound by the contracts and other rules that give them power to act, and an arbitrator who throws aside those rules and implements his own brand of industrial justice oversteps his powers, such that the resulting award must be set aside.

Conclusion

The court affirmed the district court's order requiring the USOC to nominate Lindland for the Olympic team and denied Sieracki's petition to confirm the separate arbitration award.

Affirmed.

Who won?

Matt Lindland prevailed in this case as the court upheld the arbitration award that mandated his nomination to the Olympic team. The court emphasized that the USOC and USA Wrestling had acted in concert to defy the judicial order, and thus the USOC was bound by the injunction to comply with the nomination of Lindland. The court's ruling reinforced the importance of adhering to arbitration awards and judicial orders in the context of Olympic athlete nominations.

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Major League Baseball Players Ass’n v. Garvey, 532 U.S. 504, 532 U.S. 1015, 121 S.Ct. 1724, 149 L.Ed.2d 740, 167 L.R.R.M. (BNA) 2134, 69 USLW 3719, 69 USLW 3725, 01 Cal. Daily Op. Serv. 3826, 2001 Daily Journal D.A.R. 4697, 14 Fla. L. Weekly Fed. S 236, 2001 DJCAR 2401

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