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The Third Circuit Court of Appeals affirmed a district court’s dismissal of claims filed against an arbitration administrator based on the doctrine of arbitral immunity. The doctrine protects both arbitrators and arbitration administrators.
In Sathianathan v. Pacific Exchange, Inc., No. 06-3783, 2007 WL 2686847 (3d Cir. Sept. 14, 2007), Sathianathan lost an arbitration administered by Pacific Exchange. After an unsuccessful attempt at challenging the arbitration award, Sathianathan filed suit against Pacific Exchange and some of its employees. The district court dismissed Sathianathan’s claims based on the doctrine of arbitral immunity.
On appeal, the Court rejected Sathianathan’s argument that the district court erred in ordering dismissal. The Court held that all claims against Pacific Exchange “are barred by the doctrine of arbitral immunity.”
Arbitral immunity shields arbitrators from liability for acts done within the purview of their arbitral responsibilities. This immunity has been “extended to the boards sponsoring the arbitration.” See Corey v. N.Y. Stock Exch., 691 F.2d 1205, 1209 (6th Cir. 1982).
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