Arbitrator Did Not Act with ‘Evident Partiality’ in Issuing Award, 2nd Cir. Affirms

NEW YORK - An arbitration award should not be vacated for evident partiality because no real conflict was created by a relationship between the arbitrator's law firm and the parent company of a potential witness, a federal appeals court has affirmed.

On Feb. 11, the 2nd Circuit U.S. Court of Appeals also upheld a trial court’s ruling that the award was not procured by "undue means" because both parties were allowed to submit substantial briefing to the American Arbitration Association before it determined the arbitrator should not be disqualified.

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