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A federal court in Maine held that a party’s failure to draw an arbitrator’s attention to a document did not amount to fraud on the arbitrator and that the arbitrator did not manifestly disregard the law.
In Sleeper Farms v. Agway, Inc., No. 02-CV-35-B-S, 2006 WL 3114482 (D. Maine Nov. 1, 2006), Sleeper asked the Court to vacate an arbitration award for fraud on the arbitrator and manifest disregard of the law.
First, Sleeper argued that Agway committed fraud on the arbitrator because Agway discovered a letter during the arbitration proceedings and did not submit the letter to the arbitrator. However, the Court held that these actions did not amount to fraud on the arbitrator because Sleeper failed to show that the letter was not discoverable through the exercise of due diligence.
Second, Sleeper argued that the arbitrator manifestly disregarded the law by disregarding the Maine Potato Licensing Act. However, the portion of the arbitration award that Sleeper pointed to in claiming manifest disregard of the law related to Sleeper’s breach of contract claims, not the applicability of the Potato Act. The arbitrator discussed claims under the Potato Act in a different section of the arbitration award.
Therefore, the Court held that the arbitrator’s decision to award damages under the Potato Act did not amount to manifest disregard of the law. The Court confirmed the arbitration award in Agway’s favor.
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