Hall Street v. Mattel

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Hall Street v. Mattel
Court Supreme Court of the United States
Citation 552 U.S. 576
Date decided March 25, 2008
Appealed from 9th Circuit

Facts

  • Mattel, Inc. = "Mattel" = plaintiff
  • Hall Street Associates, L.L.C. = "Hall Street" = defendant = proprietor
  • Mattel leased property from Hall Street in Oregon. However, the water in the property was polluted.
Hall Street wanted remuneration from Mattel for the cleanup.

Procedural History

The 2 parties took the indemnity question to arbitration.

They agreed that a court could vacate or modify the arbitration order if the legal conclusion was erroneous.

Initially, the arbitrator found for Mattel. Nevertheless, Mattel lost in the district court.

On remand, the arbitrator found for Hall Street.

Issues

Can parties contractually broaden the scope of judicial review available under the Federal Arbitration Act?

Arguments

Mattel argued that the district court shouldn't review the arbitration order.

Holding

No. Parties can't contractually broaden the scope of judicial review available under the act.

Judgment

Judgment of 9th Circuit vacated & remanded

Reasons

David Souter: Federal Arbitration Act:

  • Section 10: fraud or corruption provides for vacating the award
  • Section 11: mistakenly describing the award recipient provides for modifying the award
  • Neither section: erroneous conclusion of law

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