Hall Street Associates, L.L.C. v. Mattel, Inc. case brief summary
145 F. Supp. 2d 1211
CASE SYNOPSIS:Appellant challenged a judgment of the United States District Court for the District of Oregon based on an arbitration agreement.
OVERVIEW:
-The district court entered a judgment based on the parties' arbitration agreement.
-On appeal, the court held that the terms of the agreement controlling the mode of judicial review were unenforceable and severable.
-Evidence that the parties intended that the agreement should fail if the standard of review provision failed did not change the rule.
-Thus, the court vacated the judgment.
-The court directed that on remand, the district court was to return to the application to confirm the original arbitration award (not the subsequent award revised after reversal) and would confirm that award unless it determined that the award should be vacated on the grounds allowable under 9 U.S.C.S. § 10, or modified or corrected under the grounds allowable under 9 U.S.C.S. § 11.
ANALYSIS:
-The court affirmed the district court's separate finding that defendant was within its rights in terminating the lease.
-Although the lease termination provision suggested a possible scrivener's error when the lease was amended, no mistake was claimed nor reformation sought, and the parol evidence rule required that the integrated agreement be enforced as written without consideration of extrinsic evidence.
OUTCOME: The court vacated the district court's judgment based on the arbitration agreement and remanded to the district court with directions. The court affirmed the district court's separate finding that defendant was within its rights in terminating the lease.
ISSUE:
Can a federal court enforce an arbitration agreement that provides for more expansive judicial review of an arbitration award than the narrow standard of review provided for in the Federal Arbitration Act?
HOLDING:
-The provisions of the FAA are exclusive and cannot be expanded through contractual agreement.
---
Interested in learning how to get the top grades in your law school classes? Want to learn how to study smarter than your competition? Interested in transferring to a high ranked school?
-->
145 F. Supp. 2d 1211
CASE SYNOPSIS:Appellant challenged a judgment of the United States District Court for the District of Oregon based on an arbitration agreement.
OVERVIEW:
-The district court entered a judgment based on the parties' arbitration agreement.
-On appeal, the court held that the terms of the agreement controlling the mode of judicial review were unenforceable and severable.
-Evidence that the parties intended that the agreement should fail if the standard of review provision failed did not change the rule.
-Thus, the court vacated the judgment.
-The court directed that on remand, the district court was to return to the application to confirm the original arbitration award (not the subsequent award revised after reversal) and would confirm that award unless it determined that the award should be vacated on the grounds allowable under 9 U.S.C.S. § 10, or modified or corrected under the grounds allowable under 9 U.S.C.S. § 11.
ANALYSIS:
-The court affirmed the district court's separate finding that defendant was within its rights in terminating the lease.
-Although the lease termination provision suggested a possible scrivener's error when the lease was amended, no mistake was claimed nor reformation sought, and the parol evidence rule required that the integrated agreement be enforced as written without consideration of extrinsic evidence.
OUTCOME: The court vacated the district court's judgment based on the arbitration agreement and remanded to the district court with directions. The court affirmed the district court's separate finding that defendant was within its rights in terminating the lease.
ISSUE:
Can a federal court enforce an arbitration agreement that provides for more expansive judicial review of an arbitration award than the narrow standard of review provided for in the Federal Arbitration Act?
HOLDING:
-The provisions of the FAA are exclusive and cannot be expanded through contractual agreement.
---
Interested in learning how to get the top grades in your law school classes? Want to learn how to study smarter than your competition? Interested in transferring to a high ranked school?
-->
No comments:
Post a Comment