3rd Cir. Upholds Award, Says Fraudulent Conduct Not Material

PHILADELPHIA - A federal appeals court has upheld an arbitration award, affirming that although one of the parties fraudulently withheld evidence until after the award was issued, it was not material to the outcome of the proceeding. International Brotherhood of Teamsters, Local 701 v. CBF Trucking Inc., No. 10-3044 (3rd Cir.).

The 3rd Circuit U.S. Court of Appeals explained in an Aug. 1 opinion that under the Federal Arbitration Act, a court may only vacate an award if the fraudulent conduct "materially relates to an issue in the arbitration."

CBF provides shipping services to the United States Postal Service. …