Quezada v. Bechtel OG & C Construction Services, Inc., No. 19-20042 (5th Cir. 2020)Annotate this Case
The Fifth Circuit affirmed the district court's confirmation of an arbitrator's award under the Federal Arbitration Act (FAA). Bechtel and its former employee entered arbitration on the employee's claims of disability discrimination, failure to accommodate, and retaliation.
The court held that the district court correctly concluded it had jurisdiction to entertain the motions submitted by both parties. On the merits, the court held that Bechtel's first argument, that the arbitrator exceeded his authority by misapplying Fifth Circuit law, misunderstands the limited review of arbitration awards under the FAA. The court was also correct in denying vacatur based on Bechtel's claim that the arbitration rules agreed to by the parties required the arbitrator to follow the Federal Rules of Civil Procedure, which, according to Bechtel, did not authorize the arbitrator to reconsider its interim award that only granted $500 in nominal damages. The court explained that Bechtel's argument ignores the fact that the employee dispute resolution program also contains a provision stating that either party may file a motion for reconsideration with the arbitrator.