United States Fourth Circuit

A decision vacating an arbitration panel's award of compensatory damages in favor of three financial advisors arising from their claims of wrongful discharge, pursuant to the rules of the National Association of Securities Dealers (NASD), is affirmed where: 1) the district court did not abuse its discretion in remanding the award to the arbitration panel for clarification of the bases of the award; 2) the arbitration panel committed no mere error of law, rather, by rendering an award whose underlying legal basis exceeded the bounds of arbitrable employment-related disputes cognizable under NASD Rule 10101 as interpreted in Zandford v. Prudential-Bache Secs., Inc., 112 F.3d 723 (4th Cir. 1997), the panel exceeded its powers under 9 U.S.C. section 10(a)(4).

Appellate Information

• Argued 10/27/2009
• Decided 02/22/2010
• Published 02/22/2010

Judges

• Before WILKINSON, DUNCAN, and DAVIS, Circuit Judges.

Court

• United States Fourth Circuit

Counsel

• For Appellees:
  
• ARGUED:Jay J. Levit, Law Office of Jay J. Levit, Glen Allen, Virginia; Scott Gregory Crowley, Sr., Crowley & Crowley, Richmond, Virginia, for Appellants. Stephen Grey Cochran, Haight, Tramonte, Siciliano, Flask & Yeonas, PC, Vienna, Virginia, for Appellee. ON BRIEF:Victor M. Glasberg, Victor M. Glasberg & Associates, Alexandria, Virginia, for Appellee.