DT-Trak Consulting, Inc. v. Prue

Summary

The South Dakota Supreme Court reviewed DT-Trak Consulting, Inc.’s challenge to an arbitration award in favor of Dan Prue under a stock purchase agreement. DT-Trak argued that its selected arbitrator demonstrated evident partiality and that the arbitration panel failed to provide sufficient findings of fact and conclusions of law. The court affirmed the circuit court’s decision confirming the award, concluding that the alleged partiality was unsupported and that the panel’s written findings and conclusions satisfied the agreement.

Holdings

1. The court declined to decide whether the Federal Arbitration Act or the South Dakota Arbitration Act controlled because the result was the same under either statute.
2. The arbitration award was not subject to vacatur for evident partiality because DT-Trak failed to establish that the arbitrator or the arbitrator's law firm had undisclosed dealings demonstrating a reasonable impression of partiality or improper motive.
3. The arbitration panel did not exceed its authority because its written award contained findings of fact and conclusions of law sufficient to satisfy the stock purchase agreement and support the award.

Questions Presented

1. Whether the parties' South Dakota choice-of-law provision preempted or displaced application of the Federal Arbitration Act.
2. Whether the arbitration award had to be vacated for evident partiality by an arbitrator selected by DT-Trak.
3. Whether the arbitration panel exceeded its authority by failing to provide sufficient findings of fact and conclusions of law.

Disposition

affirmed