2nd Circuit Establishes Standard for Vacating Arbitration Award

In a case of first impression, the 2nd U.S. Circuit Court of Appeals ruled that an undisclosed relationship between a party and its party-appointed arbitrator constitutes evident partiality if the relationship violates a contractual requirement of disinterestedness or prejudicially affects the award. Case: Certain Underwriting Members of Lloyds of London v. Florida Department of Financial Services, No. 17-1137-cv, 06/07/02018, published. Facts and procedural history: The Insurance Co. of the Americas insures workers’ compensation claims in the construction industry. Certain Under...