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Citing state policy favoring arbitration as an alternative to litigation, and noting a court’s limited ability to review awards, the Iowa Court of Appeals reversed a lower court ruling vacating ten arbitration awards when no application to vacate was made.

In MBNA America Bank, N.A. v. Boyce, No. 04-1733, 2006 WL 2265297 (Iowa App. Aug. 09, 2006), MBNA filed ten separate motions to confirm arbitration awards. None of the defendants contested the motions.

On its own initiative, the district court denied each motion, citing an alleged absence of a written agreement to arbitrate. In five cases, the court found that, assuming there were agreements to arbitrate, the contracts were contracts of adhesion and unenforceable.

On appeal, the Court noted that the law favors arbitration and that court involvement in the process is very limited. The Court also noted the rule that under Iowa Code section 679A.11, a court must confirm an arbitration award unless a timely ground to correct or vacate the award is filed.

In this case, no defendant filed a motion to vacate the arbitration awards. Also, the trial court’s reasons for denying the motions were not established by the evidence in the record. As such, it was improper to deny the motions to confirm the arbitration awards, and the Court remanded the case with instructions to confirm the awards.

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