A District Court in the Sixth Circuit has confirmed an arbitration award in a products liability injury matter, rejecting a contention that the award should be vacated due to the failure of one of three arbitrators to disclose that he had been counsel of record in several cases years ago in which counsel for one of the parties to the arbitration was either co-counsel or counsel for another party. The Court found that the Sixth Circuit had stated that the review of an arbitral award is governed by “one of the narrowest standards of judicial review in all of Ameican jurisprudence.” The Court found that no reasonable person would find that the presence of the two attorneys in the same lawsuits constituted a conflict of interest or resulted in bias, fraud or corruption. Uhl v. Komatsu Forklift Co., Case no. 04-10148 (USDC E.D. Mich. Dec. 8, 2006).
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