Economos v. Liljedahl Bros., Inc., 279 Conn. 300

Summary

The Supreme Court of Connecticut affirmed the Appellate Court's reversal of a trial court order vacating an arbitration award in favor of a home improvement contractor. The court held that the arbitrator had not manifestly disregarded the law by awarding damages based in part on unsigned change orders because the applicable statutory framework was not sufficiently well defined and the record did not show that the arbitrator knowingly ignored a clearly governing legal principle.

Holdings

1. An arbitration award may be vacated for manifest disregard of the law only when all three elements are established: the error was obvious and readily perceptible to an ordinarily qualified arbitrator; the arbitrator appreciated a clearly governing legal principle but chose to ignore it; and the governing law was well defined, explicit, and clearly applicable.
2. The arbitrator did not manifestly disregard the law because the applicable law was not sufficiently well defined, explicit, and clearly applicable, and the record did not establish that the arbitrator recognized and intentionally ignored a clearly governing legal principle.

Questions Presented

1. Whether the arbitrator manifestly disregarded the law by awarding the contractor damages based on unsigned change orders under the Home Improvement Act, General Statutes § 20-429(a).
2. Whether the Appellate Court properly reversed the trial court's vacatur of the arbitration award and denial of confirmation.

Disposition

affirmed