Department of Transportation v. White Oak Corp., 319 Conn. 582

Summary

The Connecticut Supreme Court reviewed whether an arbitration panel exceeded its authority by deciding White Oak Corporation’s claim for return of liquidated damages after rejecting its wrongful-termination claim. The court concluded that the prior injunction proceedings did not limit the arbitration to a single wrongful-termination claim and reversed the Appellate Court’s judgment.

Holdings

1. The prior judgment did not limit White Oak to a single wrongful-termination claim. Its reference to wrongful termination functioned as an umbrella description encompassing the related categories of claims and damages identified in the notice and demand, including the liquidated-damages claim.
2. The arbitration panel did not exceed its authority by adjudicating White Oak's liquidated-damages claim and awarding return of the $5,343,000 withheld by the Department, together with prejudgment interest.
3. White Oak's notice and demand were more than sufficient to satisfy § 4-61 because they informed the Department of the general nature of the liquidated-damages claim.
4. The court did not need to decide whether the Department waived de novo judicial review by submitting arbitrability to the arbitration panel because the liquidated-damages claim satisfied § 4-61 even assuming de novo review was available.

Questions Presented

1. Whether the prior Superior Court judgment in the Department's injunction action limited the Bridgeport arbitration to a single wrongful-termination claim.
2. Whether the arbitration panel exceeded its authority by awarding White Oak return of liquidated damages and prejudgment interest after rejecting the wrongful-termination claim.
3. Whether White Oak's notice and demand for arbitration satisfied the jurisdictional notice requirements of General Statutes § 4-61.
4. Whether the Department was entitled to de novo judicial review of the arbitrability of the liquidated-damages claim after submitting that issue to the arbitration panel.

Disposition

reversed_and_remanded