Matter of Light & Wonder, Inc. v. Mohawk Gaming Enters. LLC

Summary

The Appellate Division, First Department affirmed the lower court's denial of a petition to vacate an arbitrator's class determination award and granted the cross-motion to confirm the award. Petitioners failed to establish any statutory basis for vacatur under the Federal Arbitration Act, including manifest disregard of the law or exceeding powers. The arbitrator properly considered relevant authorities and determined that the class members' agreements were substantially similar, with any differences not precluding class certification.

Holdings

1. Petitioners failed to establish that the arbitrator manifestly disregarded the law; Lamps Plus and Stolt-Nielsen do not address class certification, so the law was not well-defined and clearly applicable to the absent class member contracts.
2. The arbitrator did not exceed his powers because he stayed within his delegated task of interpreting the contract and addressed relevant authorities and evidence.

Questions Presented

1. Whether the arbitrator manifestly disregarded the law under the FAA by certifying a class without requiring each absent class member's contract to show affirmative consent to class arbitration.
2. Whether the arbitrator exceeded his powers under the FAA.

Disposition

affirmed