In a February 26, 2008 post, we discussed an opinion of the Sixth Circuit Court of Appeals which held that claims asserted in arbitration by members of a settlement class were barred if they related to the settled claims because the claimants had not opted out of the class-wide settlement of the claims. The case was remanded to the arbitration panel to clarify the basis for the award. The panel confirmed that the award was based solely on the matters that were encompassed by the settlement. In a second appellate round, the court confirmed the vacation of the award due to the bar of the settlement, and also affirmed the dismissal of cross-claims by the district court. Rich v. Spartis, No. 06-1723 (6th Cir. Dec. 16, 2008).