Plaintiff Hartford Steam Boiler Inspection and Insurance Company (“Hartford”) appealed a decision permitting a court to remand a dispute over an arbitral award to the arbitration panel for clarification of that award. Hartford argued that the court’s holding was overruled by the U.S. Supreme Court’s decision in Hall Street Associates, LLC v. Mattel, Inc., 552 U.S. 576 (2008).
The Connecticut appellate court affirmed the trial court’s decision, finding that Hall Street “made no mention whatsoever” of whether a court could remand a dispute over an arbitration award to the panel for clarification. Rather, the court noted that Hall Street involved whether parties to an arbitration agreement could supplement the statutory grounds for vacating or modifying an arbitration award under the Federal Arbitration Act (the Supreme Court held that parties cannot). Thus, the appellate court found that Hall Street was inapplicable, and that the Supreme Court did not alter the body of federal and state law permitting a court to remand a dispute over the clarity of an arbitration award to the arbitrators.
Click here to review a copy of the appellate court’s decision, entitled Hartford Steam Boiler Inspection & Insurance Company v. Underwriters at Lloyd’s & Companies Collective, et al., (Ct. App. Ct. 2010).