• Skip to primary navigation
  • Skip to main content
  • Skip to primary sidebar

Reinsurance Focus

New reinsurance-related and arbitration developments from Carlton Fields

  • About
    • Events
  • Articles
    • Treaty Tips
    • Special Focus
    • Market
  • Contact
  • Exclusive Content
    • Blog Staff Picks
    • Cat Risks
    • Regulatory Modernization
    • Webinars
  • Subscribe
You are here: Home / Arbitration / Court Decisions / Sixth Circuit Confirms Arbitration Award Despite Argument That Case Was International and Beyond Arbitrator’s Authority

Sixth Circuit Confirms Arbitration Award Despite Argument That Case Was International and Beyond Arbitrator’s Authority

November 1, 2024 by Benjamin Stearns

The arbitration award stemmed from the pro se complaint of Joseph Ruzindana for wrongful termination against his former employer, FCA US. In the arbitration, Ruzindana claimed that he was harassed and discriminated against by FCA US.

After the arbitrator rendered an award in favor of FCA US, Ruzindana filed a motion to vacate, arguing that the case “was an international one beyond the Arbitrator’s and state Authority because some of FCA US’s vehicles would be sold in Brazil and some of his colleagues were located in Brazil.” However, the arbitration agreement between the parties authorized the arbitrator to decide “whether the challenged personnel decision or action was (1) lawful under applicable federal, state and local law, or (2) consistent with the Company’s At Will employment policy.” As a result, the resolution of Ruzindana’s employment-related claims fell within the arbitrator’s powers, regardless of any connection between those claims and Brazil.

Under the Federal Arbitration Act, a district court may vacate an arbitration award under only four circumstances:

  1. Where the award was procured by corruption, fraud, or undue means;
  2. Where there was evident partiality or corruption in the arbitrators, or either of them;
  3. Where the arbitrators were guilty of misconduct in refusing to postpone the hearing, upon sufficient cause shown, or in refusing to hear evidence pertinent and material to the controversy, or of any other misbehavior by which the rights of any party have been prejudiced; or
  4. Where the arbitrators exceeded their powers, or so imperfectly executed them that a mutual, final, and definite award upon the subject matter submitted was not made.

Ruzindana did not allege that the arbitration award was procured by corruption, fraud, or undue means or that the arbitrator was partial, corrupt, or guilty of any misconduct. He did allege that the matter was “beyond the arbitrator’s” authority but, as noted above, the district court and the Sixth Circuit held to the contrary.

Because Ruzindana did not satisfy any of the grounds for vacating an arbitration award under 9 U.S.C. § 10(a), the Sixth Circuit held that the district court properly denied his motion to vacate the arbitration award.

Ruzindana v. FCA US, LLC, No. 23-1649 (6th Cir. July 3, 2024).

Filed Under: Arbitration / Court Decisions, Jurisdiction Issues

Primary Sidebar

Carlton Fields Logo

A blog focused on reinsurance and arbitration law and practice by the attorneys of Carlton Fields.

Focused Topics

Hot Topics

Read the results of Artemis’ latest survey of reinsurance market professionals concerning the state of the market and their intentions for 2019.

Recent Updates

Market (1/27/2019)
Articles (1/2/2019)

See our advanced search tips.

Subscribe

If you would like to receive updates to Reinsurance Focus® by email, visit our Subscription page.
© 2008–2025 Carlton Fields, P.A. · Carlton Fields practices law in California as Carlton Fields, LLP · Disclaimers and Conditions of Use

Reinsurance Focus® is a registered service mark of Carlton Fields. All Rights Reserved.

Please send comments and questions to the Reinsurance Focus Administrators

Carlton Fields publications should not be construed as legal advice on any specific facts or circumstances. The contents are intended for general information and educational purposes only, and should not be relied on as if it were advice about a particular fact situation. The distribution of this publication is not intended to create, and receipt of it does not constitute, an attorney-client relationship with Carlton Fields. This publication may not be quoted or referred to in any other publication or proceeding without the prior written consent of the firm, to be given or withheld at our discretion. To request reprint permission for any of our publications, please contact us. The views set forth herein are the personal views of the author and do not necessarily reflect those of the firm. This site may contain hypertext links to information created and maintained by other entities. Carlton Fields does not control or guarantee the accuracy or completeness of this outside information, nor is the inclusion of a link to be intended as an endorsement of those outside sites. This site may be considered attorney advertising in some jurisdictions.