Part II.A: What to Make of Oxford?
In our last post (here) we discussed the U.S. Supreme Court’s recent decision in Oxford Health Plans LLC v. Sutter, No. 12-135, slip op. (U.S. June 10, 2013), which, among other things, reaffirmed that Section 10(a)(4) of the Federal Arbitration Act (“FAA”) authorizes judicial review of FAA-governed-arbitration-award outcomes based on the labor-arbitration-derived “manifest disregard of the agreement” standard. This post, which has been divided into three segments, discusses what to make of Oxford. This part A addresses the scope of Oxford, including whether it undermines Stolt-Nielsen and whether it authorizes arbitrators to disregard or modify the clear terms of the parties’ agreement. Continue Reading »