Farnsworth, III v. Towboat Nantucket Sound, Inc., No. 14-1903 (1st Cir. 2015)Annotate this Case
Plaintiff entered into a salvage contract with Defendant to obtain help when his boat went aground one night. Plaintiff later attempted to rescind the contract, claiming that he signed the contract under duress and disputing the sum owed to Defendant. The parties submitted the dispute to a panel of arbitrators pursuant to a binding arbitration clause in the salvage contract. Plaintiff then filed this lawsuit seeking a preliminary injunction against the arbitration and a declaration that the salvage contract was unenforceable. The district court denied the motion and stayed the case pending the outcome of the arbitration. The arbitration panel found in favor of Defendant and ordered Plaintiff to pay a salvage award. The district court affirmed the award. Plaintiff appealed, arguing that the district court erred in confirming the arbitration award without first addressing his claim that the arbitration clause was unenforceable. The First Circuit affirmed, holding that, where Plaintiff’s challenge to the validity of the arbitration clause itself came only after Defendant moved to confirm the panel’s award, the district court had no proper basis on which to refuse to confirm the arbitration panel’s award.