In a non-reinsurance arbitration under the auspices of the American Arbitration Association, a three member panel signed an award, which the AAA found was not final due to continuing discussions among the members of the panel. Three days later, the panel issued a final award, which the AAA sent to the parties. A dispute arose as to which award should be confirmed. The District Court respected the authority of the AAA to determine the finality of awards, and confirmed the latter award. The US Court of Appeals for the Second Circuit affirmed. The Courts also rejected a contention that the latter award was in manifest disregard of law. Appel Corp. v. Katz, Case No. 02-8879 (2nd Cir. Feb. 2, 2007).
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