Petitioner Daniel Olson brought an action in federal court seeking vacatur of an award against him in arbitration of an employment dispute. He challenged the arbitration award for lack of a “reasoned opinion” and failure of the arbitrator to rule on all of the evidentiary issues and claims submitted. The district court denied the motion to vacate and Olson appealed.
In the Ninth Circuit’s opinion, the Court reminded Plaintiff that “Arbitrators have no obligation to give their reasons for an award” and that here, “the arbitration award included two bases for the arbitrator’s determination that [Defendant] was the prevailing party, which provides enough of the arbitrator’s reasoning to facilitate the limited review available under the FAA.”
The Court further rejected Plaintiff’s claims that the arbitrator did not rule on all of the evidentiary issues, stating “arbitrators’ awards are not judicial opinions. The proceedings the arbitrator conducts are generally informal, lacking most of the fixed rules of procedure and evidence.” As to Plaintiff’s contention that the arbitrator failed to rule on all the claims submitted for arbitration, that too was rejected as “the award states that all claims not expressly granted herein are hereby, denied.”