Williamson Farm v. Diversified Crop Ins. Servs. (P)

Despite the strong presumption in favor of confirming arbitration awards pursuant to the Federal Arbitration Act, a crop insurer met its heavy burden to prove that the arbitrator exceeded her powers by awarding extra-contractual damages to a farm, contrary to both the policy and binding authority from the Federal Crop Insurance Corporation.

Since the arbitrator provided only a single amount of damages rather than a breakdown of the award by contract and non-contract claims, this court has no way to distinguish what amount the arbitrator may have awarded in contractual damages (which were within the arbitrator’s authority to award) and what amount the arbitrator awarded for extra-contractual damages (which exceeded her authority). Therefore, the district court did not err in vacating the entire award.

Affirmed.

Williamson Farm v. Diversified Crop Ins. Servs. (P), No. 18-1463, Feb. 27, 2019. 4th Cir. (Thacker) from EDNC at Raleigh (Dever).



Categories: 4th U.S. Circuit Court of Appeals, Opinions, Published

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