Worldwide Aircraft Services, Inc. d/b/a Jet ICU v. Cigna Health and Life Insurance Company

Summary

The United States District Court for the Middle District of Florida denied Worldwide Aircraft Services, Inc. d/b/a Jet ICU’s petition to vacate a No Surprises Act independent dispute resolution arbitration award selecting Cigna’s offer of $0. The court held that the petitioner failed to plead the grounds for vacatur with particularity and failed to show fraud, bias, misconduct, or that the arbitrator exceeded its authority under the Federal Arbitration Act. The court directed entry of judgment for Cigna and closure of the case.

Holdings

1. A petition seeking to vacate an arbitration award must state the grounds for vacatur with particularity; Worldwide's vague and conclusory allegations did not satisfy that requirement.
2. The petition to vacate was denied because Worldwide failed to meet its heavy burden of establishing any statutory ground for vacatur, including excess of authority, evident partiality, misconduct, refusal to hear pertinent evidence, fraud, or misrepresentation.
3. The No Surprises Act IDR award was binding on the parties absent fraud or misrepresentation, and Worldwide did not establish either circumstance.

Questions Presented

1. Whether the petition adequately pleaded particularized grounds for vacating the arbitration award.
2. Whether the arbitrator exceeded its authority, acted with evident partiality, denied Worldwide adequate notice or an opportunity to be heard, or improperly refused to consider pertinent and material evidence under the Federal Arbitration Act.
3. Whether the No Surprises Act IDR arbitration award should be vacated.

Disposition

other