Weiss v. Sallie Mae, Inc., No. 18-2362 (2d Cir. 2019)Annotate this Case
Plaintiff appealed the district court's grant of Sallie Mae's motion to vacate an arbitration award based on the arbitrator's failure to apply a general release provision in a settlement agreement that barred all of plaintiff's claims.
The Second Circuit held that the arbitrator ignored the unambiguous terms of the general release and concluded that the award of statutory damages for a subset of plaintiff's claims was irreconcilable with the arbitrator's determination that plaintiff was a member of the settlement class and that she received adequate notice of its terms; because the arbitrator failed to provide an explanation for these mutually exclusive determinations, the court was unable to ascertain whether the arbitrator adhered to applicable substantive law as required by the parties' arbitration agreement and whether the arbitral award was issued in manifest disregard of the law; and therefore the court vacated and remanded for clarification.