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United States First Circuit

First State Insurance Company v. National Casualty Company, 14-1644

After underlying arbitration proceedings had run their course between the parties in this case, appellees First State Insurance Company and New England Reinsurance Corporation separately petitioned to confirm the panel's final award. The district court consolidated the two confirmation petitions and, after a hearing, summarily confirmed both the contract interpretation award and the final arbitration award. The district court further denied appellant National Casualty Company's cross-petition to vacate the challenged award. The judgment of the district court is affirmed, where: 1) the arbitration clause here contains an "honorable engagement" provision, which authorized the arbitrators to grant equitable remedies; 2) the reservation of rights procedure adumbrated in the contract interpretation award is such an equitable remedy; and 3) a federal court's authority to defenestrate an arbitration award is extremely limited, and it is further limited by the existence of an "honorable engagement" provision.

Appellate Information

  • Decided 03/20/2015
  • Published 03/20/2015


  • Selya


  • United States First Circuit


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