The Second Circuit, in a Summary Order, reversed a decision of a district court in Connecticut which found an arbitral panel’s award in manifest disregard of a Connecticut statute. Sotheby’s Int’l Realty, Inc. v. Relocation Group. LLC, 2015 WL 64265 (2nd. Cir. Jan. 6, 2015). Applying the great deference given to arbitral awards, the Court stated, “[a] motion to vacate filed in federal court is not an occasion for a de novo review of an arbitral award.” The district court appeared to have done just that, engaging in an extensive analysis of the Connecticut statute, including reference to numerous unpublished opinions, which the Second Circuit found “problematic”. [Read more…]
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