Driver v. SI Corporation, 139 Idaho 423

Summary

The Idaho Supreme Court reviewed challenges to an arbitration award arising from the sale of BonTerra America, Inc. to SI Corporation. The court held that SI failed to timely state specific grounds for vacating or modifying the award, affirmed confirmation of the arbitration award, and held that attorney fees could be awarded for the confirmation proceedings and on appeal. The case was remanded for the district court to determine the fees incurred below.

Holdings

1. An application to vacate or modify an arbitration award must identify the specific statutory grounds for relief within the ninety-day period imposed by Idaho Code sections 7-912 and 7-913. SI's motion, which did not identify specific grounds until its supporting brief was filed after the deadline, was insufficient.
2. A cross-appeal was unnecessary because the Drivers sought only to sustain the judgment on a reason presented below, rather than obtain additional or different relief.
3. Attorney fees may be awarded under Idaho Code section 7-914 for proceedings to confirm an arbitration award because the statute's authorization of costs and disbursements includes attorney fees incurred in those proceedings.
4. The Drivers were entitled to attorney fees on appeal in the court's discretion because SI's appeal challenged the arbitration award on grounds beyond the limited statutory scope of review.

Questions Presented

1. Whether SI's motion to vacate or modify the arbitration award adequately stated specific statutory grounds within the ninety-day period required by Idaho Code sections 7-911 and 7-912.
2. Whether the district court could consider the Drivers' challenge to the timeliness and specificity of SI's motion without a cross-appeal.
3. Whether attorney fees incurred in a proceeding to confirm an arbitration award may be awarded under Idaho Code section 7-914.
4. Whether the Drivers were entitled to attorney fees on appeal.

Disposition

reversed_and_remanded