DT-Trak Consulting, Inc. v. PrueAnnotate this Case
Dan Prue sold his majority interest in DT-Trak Consulting, a medical coding business, for a lump-sum payment and several annual payments. DT-Trak withheld an annual payment, asserting that Prue had violated the parties' stock purchase agreement. The matter proceeded to arbitration. A three-member arbitration panel made an award in Prue's favor. DT-Trak sought to vacated the award, alleging that the arbitrator it selected demonstrated evident partiality and that the panel's findings of fact and conclusions of law were insufficient. The circuit court affirmed. The Supreme Court affirmed, holding that under either the Federal Arbitration Act or South Dakota Arbitration Act, DT-Trak failed to show that the arbitration award should be vacated, as (1) there was no support that any member of the arbitration panel exhibited evident partiality; and (2) the findings of fact and conclusions of law submitted by the panel were sufficient under the requirements of the agreement.