Moore v. Omnicare, Inc., 141 Idaho 809

Summary

The Idaho Supreme Court reviewed consolidated appeals concerning an arbitration award arising from an asset purchase agreement and an employment agreement. The court held that the Idaho Uniform Arbitration Act governed, upheld prejudgment interest on the earnings holdback claim, vacated awards of attorney fees and costs that exceeded the parties’ agreement, and affirmed the refusal to award treble damages and attorney fees on the employment claim.

Holdings

1. The Idaho Uniform Arbitration Act, rather than the Federal Arbitration Act, governed the substantive arbitration issues because the parties expressly agreed that Idaho law would govern both the Asset Purchase Agreement and the Employment Agreement.
2. An arbitrator's award may be vacated under the UAA when the arbitrator exceeds the authority granted by the parties' agreement, but an award may not be set aside merely because the arbitrator allegedly made an error of law or fact.
3. The arbitration panel exceeded its authority by awarding Mednat attorney fees on the earnings-holdback claim because the Asset Purchase Agreement required each party to bear its own arbitration costs and attorney fees.
4. The district court erred by confirming the arbitration panel's award of costs on the earnings-holdback claim.
5. The arbitration panel acted within its authority by awarding prejudgment interest on the earnings-holdback claim.
6. Moore's damages under the Employment Agreement were not wages for services rendered and therefore were not subject to mandatory trebling under Idaho Code section 45-615.

Questions Presented

1. Whether the Idaho Uniform Arbitration Act or the Federal Arbitration Act governed the parties' arbitration agreements.
2. Whether the arbitration panel exceeded its authority by awarding attorney fees and costs on Mednat's earnings-holdback claim.
3. Whether the arbitration panel had authority to award prejudgment interest on the earnings-holdback claim.
4. Whether Moore's damages under the Employment Agreement were wages subject to mandatory trebling under Idaho Code section 45-615.
5. Whether Moore or Omnicare was entitled to attorney fees on appeal.

Disposition

reversed