Blakeslee Arpaia Chapman, Inc. v. Department of Transportation, 273 Conn. 746

Summary

The Supreme Court of Connecticut affirmed the denial of a contractor's application to vacate or modify an arbitration award arising from delays in a state bridge-construction contract. The court held that, under an unrestricted arbitration submission, the award was not reviewable for ordinary errors of fact or law, and the arbitrators' alleged inconsistency between their findings and award did not constitute manifest disregard of the law. The court concluded that the arbitrators complied with General Statutes § 4-61(e) and that the narrow grounds for vacatur under General Statutes § 52-418(a)(4) were not established.

Holdings

1. An arbitration award rendered pursuant to an unrestricted submission is not subject to judicial review for ordinary errors of law or fact; review is limited to whether the award conforms to the submission or falls within a recognized ground for vacation.
2. An award may be vacated under General Statutes § 52-418(a)(4) for manifest disregard of the law only when the alleged error is obvious, the arbitrators appreciated a clearly governing legal principle but chose to ignore it, and that principle is well defined, explicit, and clearly applicable.
3. General Statutes § 4-61(e) requires arbitrators to issue written findings of fact, a decision interpreting the contract and applying it to the facts found, and an award, but it does not impose a clearly defined requirement that the award be mathematically or substantively consistent with every finding of fact.

Questions Presented

1. Whether the arbitrators' failure to award the full amounts requested for home office overhead, liquidated damages, and interest was inconsistent with their findings of fact and constituted a manifest disregard of the law under General Statutes § 52-418(a)(4).
2. Whether General Statutes § 4-61(e) requires an arbitration award to be consistent with the arbitrators' written findings of fact.
3. Whether the plaintiff's challenge to the arbitrators' damages determinations impermissibly sought judicial review of factual and legal determinations made under an unrestricted arbitration submission.

Disposition

affirmed