HayDay Farms, Inc. v. FeeDx Holdings, Inc.

Summarized by:

  • Court: 9th Circuit Court of Appeals Archives
  • Area(s) of Law: Arbitration
  • Date Filed: 12-19-2022
  • Case #: 21-55650
  • Judge(s)/Court Below: Nelson, J. for the Court; Smith, J.; and Darin, J.
  • Full Text Opinion

Under Section 10(a)(4) the arbitration award must show a manifest disregard for law or be completely irrational to be thrown out.

HayDay Farms was awarded $21 million in an arbitration awarded against FeeDx Holdings for breach of contract. FeeDx asked for the panel to vacate under 9 U.S.C. § 10(a)(4). Under Section 10(a)(4) the arbitration award must show a manifest disregard for law or be completely irrational to be thrown out. The award was not irrational because it did not ignore controlling terms and drew its essence from the parties’ agreement. The Court focused on how the arbitration made their decisions and whether their were rational decisions being made to award one way or the other. AFFIRMED in part, REVERSED in part, REMANDED.

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