A collection of the most recent U.S. international arbitration decisions is available here. Decisions can be quickly retrieved by using the filter tools below.
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Interceptor Ignition Interlocks, Inc. v. AT&T Mobility Services LLC, No. 1:18-CV-04289-PKC-GWG (S.D.N.Y. Mar. 7, 2019)03/07/2019
Court granted defendant’s motion to compel arbitration and stayed all pending claims. Court found that the parties’ agreement incorporated the AAA Commercial Arbitration Rules and, under these rules, issues of arbitrability, such as the scope of the arbitration agreement, were delegated to the arbitrator.
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Egan v. Live Nation Worldwide, Inc., No. 18-1794 (3d Cir. Mar. 6, 2019)03/06/2019
Court of appeals vacated district court order’s denying defendant’s motion to compel arbitration and remanded the case for trial on the existence of an arbitration agreement. Court found that the district court relied on an incorrect summary-judgement standard when it should have held a trial to resolve the dispute of material fact concerning whether plaintiff had agreed to the arbitration clause.
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Widmer Enterprises, LLC v. Falck USA, Inc., No. 2:18-CV-11138-SDD (E.D. Mich. Mar. 6, 2019)03/06/2019
Court granted defendants’ motion to dismiss, finding that the dispute fell within a narrow arbitration provision. The dispute centered on whether the correct purchase price had been paid in a transaction where the target had understated its bad debt reserves. Court held that this was the sort of dispute which was delegated to an accounting expert by the arbitration agreement.
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Varner v. Sunrun Installation Services, Inc., No. 1:18-CV-00328-JAO-KJM (D. Hawaii Mar. 6, 2019)03/06/2019
Court granted defendant’s unopposed motion to compel arbitration of all employment-related claims, and dismissed case without prejudice.
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Snow v. ADT, LLC, No. 5:19-CV-00021-JGB-SHK (C.D. Cal. Mar. 5, 2019)03/05/2019
Court denied defendant’s motion to compel arbitration. Court rejected defendant’s argument that plaintiff’s continued employment after the initiation of an arbitration policy with an opt-out provision was sufficient to establish plaintiff implied-in-fact assent to arbitrate, finding that plaintiff was on leave when the policy was initiated and thus never received it and could not assent.
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UDI Management v. Tremblay, 1:13-CV-00085-HWW (D.V.I. Mar. 6, 2019)03/05/2019
Court denied motion to vacate an arbitration award and confirmed the award. Court found that although the courts in the Virgin Islands recognize the manifest disregard standard, petitioner did not meet its burden of proving that the arbitrator manifestly disregarded the law in making the award.
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Adell v. Cellco Partnership, No. 1:18-CV-00623-CAB (N.D. Ohio Mar. 5, 2019)03/05/2019
Court granted defendant’s motion to compel arbitration and stay proceedings under the FAA. Court rejected plaintiffs arguments that her consent to the arbitration was not voluntary and that the Class Action Fairness Act and FAA are in conflict. Court found that plaintiff’s consent was voluntary because they had the choice to take their business elsewhere.
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Freeman v. Fidelity Brokerage Services LLC, No. 3:18-CV-00947-G (N.D. Tex. Mar. 5, 2019)03/05/2019
Court denied defendant’s motion to compel FINRA arbitration, finding that plaintiffs were not signatories to the agreement containing the arbitration clause. Court rejected defendant’s argument that the plaintiff was bound to the agreement with the arbitration clause under a theory of estoppel, finding instead that plaintiff had not sought benefits under that agreement, nor had they attempted to enforce rights under that agreement.
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International Union, United Automobile, Aerospace and Agricultural Implement Workers of America v. TRW Automotive U.S. LLC, No.18-1160/1161 (6th Cir. Mar. 5, 2019)03/05/2019
Court of appeals overturned a district court’s denial of a motion to partially vacate an arbitral award. The arbitrator had ordered TRW to reinstate healthcare coverage under a specific provider and TRW claimed that the arbitrator did not arguably construe the agreement and this remedy was outside the scope of his authority. Court agreed and found that the district court should have partially vacated the award.
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Mutka v. Top Hat Imports, LLC, No. 2:18-CV-00539-SPC-MRM (M.D. Fla. Mar. 4, 2019)03/04/2019
Magistrate judge issued recommendation that court granted defendant’s motion to compel arbitration and stayed the case. Plaintiff argued that that the defendant was not a party to the arbitration agreement signed between himself and his employer, a car dealership, and thus defendant could not enforce it. Magistrate judge found that while the term “dealership” was not defined in the agreement, extrinsic evidence resolved that ambiguity and showed that defendant was a party to the agreement.
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Pang v. Samsung Electronics America, Inc., No. 4:18-CV-01882-PJH (N.D. Cal. Mar. 4, 2019)03/04/2019
Court granted defendant’s motion to compel arbitration, staying proceedings as to one plaintiff, but declined to stay proceedings for plaintiffs who had opted out of the arbitration agreement. Court found that pursuant to California law, an offer to arbitrate future disputes that was written on a brochure included in the packaging of a portable phone was not conspicuous enough that a reasonable person would be on notice of their obligation to either arbitrate future claims or opt out of the arbitration agreement. However, court held that a consumer who sought to invoke a limited warranty within the arbitration agreement’s 30 day opt out period would be on notice, and thus said plaintiff had an obligation to arbitrate.
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Camilo v. Lyft, Inc., No. 1:17-CV-09116-ALC (S.D.N.Y. Mar. 1, 2019)03/01/2019
Court granted defendant’s motion to compel arbitration and stayed the case. Court found a valid arbitration agreement, which expressly contemplated potential claims arising out of state or federal wage-hour laws at issue. Court further affirmed validity of arbitration agreements requiring individualized arbitration, following Epic Systems.
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Wallace v. Communications Unlimited, Inc., No. 4:18-CV-00503-JAR (E.D. Mo. Mar. 1, 2019)03/01/2019
Court granted defendant’s motion to compel arbitration and stayed proceedings. Court ignored plaintiff’s argument that an arbitration agreement was unenforceable because it lacked sufficient acceptance to form a contract, instead finding pursuant to Missouri state law that this challenge should be presented in arbitration because the agreement delegated issues of contract formation to the arbitrator. The court also noted that plaintiff’s did not challenge an earlier agreement which contained an identical arbitration provision.
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Economy Linen and Towel Service v. International Brotherhood of Teamsters, No.18-3369 (6th Cir. Mar. 1, 2019)03/01/2019
Court of appeals affirmed district court’s confirmation of an arbitration award. Court ignored petitioner’s arguments that the arbitrator exceeding his authority by interpreting the bargaining agreement, finding that an arbitrator’s interpretive errors were beyond the reach of the deferential review Federal courts may give an arbitration award.
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Wanamaker Nursery, Inc. v. John Deere Risk Protection, Inc., No. 4:17-CV-00077-CHS (E.D. Tenn. Feb. 28, 2019)02/28/2019
Court dismissed a case seeking vacatur of an arbitration award. Plaintiffs and defendant had previously arbitrated a dispute related to claims made on an insurance policy significant insect damage to plaintiff’s nursery. Defendants determined plaintiffs were entitled to recovery under only one of seven policies and the arbitrator issued an award finding defendant had properly paid all amounts owed. Court found that plaintiffs did not establish any grounds by which the court could overturn the award.
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The Evangelical Lutheran Good Samaritan Society v. Moreno, No. 2:16-CV-01355-JB-KRS (D.N.M. Feb. 28, 2019)02/28/2019
Court granted defendant’s motion to appoint a neutral arbitrator pursuant to the FAA. Court found that the parties failed to agree on an arbitrator and that arbitration agreement did not provide a method for appointing an arbitrator in the event that the parties failed to agree. Thus, court had authority to appoint an arbitrator pursuant to 9 USC § 5.
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Struss v. Rural Community Insurance Services, No. 2:18-CV-02187-DDC-GEB (D. Kan. Feb. 28, 2019)02/28/2019
Court granted motion to compel arbitration and stayed proceedings as to one defendant who was not bound to arbitrate claims until the conclusion of the arbitration. Court rejected plaintiff’s argument that only certain claims should be compelled to arbitration, finding that because the agreement elected that the AAA’s rules should control, the agreement delegated all issues of arbitrability to the arbitrator and the arbitrator should decide which claims were subject to arbitration.
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Chong v. 7-Eleven, Inc., No. 1:18-CV-01542-SNLJ (E.D. Penn. Feb. 28, 2019)02/28/2019
Court stayed several of plaintiff’s claims finding that they fell within the scope of an arbitration provision contained in a franchise agreement. Court rejected plaintiff’s argument that defendant had waived its right to arbitration because its motion to stay arbitrable claims was filed five months after the original complaint. Court found that defendant’s motion to stay related only to claims in plaintiff’s amended complaint and, because defendant made that motion within three weeks of the amended complaint, there was no undue delay and defendant had not waived its right to arbitration.
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Kourembanas v. Intercoast Colleges, No. 2:17-CV-00331-JAW (D. Maine Feb. 28, 2019)02/28/2019
Court granted defendant’s motion to dismiss and compel arbitration of dispute alleging breach of contract and deceptive trade practices of a nursing school. Court found that an agreement to arbitrate existed under Maine law. Plaintiffs argued that the arbitration clause itself was unconscionable, but court found that under Maine law, the clause was neither substantively nor procedurally unconscionable.
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Ellington v. Hayward Baker, Inc., No. 2:18-CV-03436-DCN (D.S.C. Feb. 28, 2019)02/28/2019
Court granted defendant’s motion to compel arbitration and dismiss the case. Court rejected plaintiff’s argument that a conflict between two agreements, one of which did not contain an arbitration provision, evinced a lack of agreement to arbitrate. Court found that none of the provisions in the agreements were in conflict with the arbitration provision.
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CAA Sports LLC v. Dogra, No. 4:18-CV-01887-SNLJ (E.D. Mo. Feb. 28, 2019)02/28/2019
Court declined to either confirm or vacate an arbitration award, and dismissed the case without prejudice. Court followed the eighth circuit’s “complete arbitration rule,” and found that it was premature to decide the issues before it because there was not a final award. Court reasoned that the award was not final because there is still a dispute over the amount of the award that must be resolved by the arbitrator.
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Castro v. Tri Marine Fish Company LLC, No. 2 :17-CV-00008-RSL (9th Cir. Feb. 27, 2019)02/27/2019
Court of appeals reversed in part and vacated in part district court’s order treating an order issued by an arbitrator in the Philippines as a foreign arbitral award and confirming the arbitrator’s order under the New York Convention. Court held there were several unique aspects of these proceedings that led it to conclude that the order was not an arbitral award within the meaning of the Convention.
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Farm v. Diversified Crop Insurance Services, No. 18-1463 (4th Cir. Feb. 27, 2019)02/27/2019
Court of appeals affirmed district court’s decision vacating an award. Court held that despite the strong presumption in favor of confirming arbitration awards pursuant to the FAA, the appellee met its heavy burden to prove that the arbitrator exceeded her powers by awarding extra-contractual damages.
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Jackson v. Royal Caribbean Cruises, Ltd, No. 3:18-CV-01699-S-BH (N.D. Tex Feb. 26, 2019)02/26/2019
Court denied defendants’ motion to compel arbitration and plaintiff’s motion for summary judgment. Court found there was no explicit or implicit agreement to arbitrate.
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Medina v. BFI Waste Services of Texas, LP, No. 5:17-CV-00906-DAE (W.D. Tex. Feb. 23, 2018)02/23/2019
Court granted defendant’s motion to compel arbitration and dismissed claims of work related negligence. Court found a valid arbitration agreement existed and that the claims were in the scope of the agreement. Plaintiff did not respond to the motion, but court did not find any issues of unconscionability, fraud or duress that might invalidate the agreement.
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Al-Ali v. Ken Garff Automotive Group, No. 2:18-CV-12687-PDB-MKM (E.D. Mich. Feb. 22, 2019)02/22/2019
Court adopted magistrate judge’s report and recommendation, converted defendants’ motion to dismiss and compel arbitration to a motion for summary judgment, and granted defendants’ motion. Magistrate judge concluded that plaintiff agreed to arbitrate claims arising from her employment, and nothing suggested that Congress intended plaintiff’s claims to be non-arbitrable or that it should be invalidated by generally applicable state-law contract defenses. Magistrate judge also concluded that because all of plaintiff’s claims were subject to arbitration, the court should dismiss plaintiff’s complaint.
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Perez-Tejada v. Mattress Firm, Inc., No. 1:17-CV-12448-DJC (D. Mass. Feb. 21, 2019)02/21/2019
Court allowed defendants’ motion to compel individual arbitration. Court concluded that (i) the parties agreed to the material terms of the arbitration agreements and had a present intention to be bound by the agreements; (ii) defendants met their burden to show adequate consideration for the agreement; (iii) defendants were entitled to invoke the arbitration agreement; (iv) the agreement was not unconscionable; and (v) the collective action waiver was enforceable.
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Gallagher v. Pepe Auto Group, No. 7:18-CV-03433-VB (S.D.N.Y. Feb. 21, 2019)02/21/2019
Court granted motion to compel arbitration as to plaintiff’s ADEA, OWBPA, NYSHRL, breach of contract, wrongful discharge, and breach of fiduciary duty claims, and denied as to plaintiff’s intentional interference with contractual relationship, intentional interference with prospective economic advantage, injurious falsehood, and libel per se claims. Court found that the second set of claims required examination of different evidence and did not require interpretation of or reference to the Employment Agreement.
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Campos v. JPMorgan Chase Bank, NA, No. 3:18-CV-06169-JSC (N.D. Cal. Feb. 21, 2019)02/21/2019
Court granted motion to compel arbitration and dismissed the case without prejudice. Court concluded that (i) the arbitration agreement was valid and covered the claims at issue; (ii) the adhesive nature of the agreement presented only a minimal degree of procedural unconscionability, and plaintiff failed to show additional factors of oppression or surprise that would render the agreement procedurally improper; (iii) plaintiff failed to demonstrate that defendant’s ability to amend or terminate the agreement was substantively unconscionable; and (iv) the discovery guideline provision was not substantively unconscionable as plaintiff failed to demonstrate that she would be unable to vindicate her rights under the agreement’s guideline limitations on discovery and the provision was not overly “harsh,” “unduly oppressive,” “one-sided as to shock the conscious,” or “unfairly one-sided.”
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Getz v. DIRECTTV, LLC, No. 1:18-CV-22802-JEM (S.D. Fla. Feb. 20, 2019)02/20/2019
Court denied defendant ViaSat, Inc.’s motion to compel arbitration. Court found that the plaintiff’s claim arose from post-agreement conduct that allegedly violates a separate, distinct federal law and is not covered by the arbitration agreement.
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Charles v. Portfolio Recovery Associates, No. 3:17-CV-00955-YY (D. Or. Feb. 20, 2019)02/20/2019
Court adopted the report and recommendation of the magistrate judge and granted defendant’s motion to compel arbitration. Magistrate judge found that (i) defendant met its burden of establishing, by a preponderance of the evidence, the existence of—and plaintiff’s assent to—the arbitration agreement; (ii) defendant established its right to invoke the arbitration provision by a preponderance of the evidence; (iii) the scope of the arbitration encompassed plaintiff’s claim; (iv) the private attorney general and class action waivers found in the arbitration provision were valid; and, (v) plaintiff had not met his burden of showing that he is entitled to a jury trial under the FAA.
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Connor v. Midland Credit Management, No. 1:18-CV-23023-JG (S.D. Fla. Feb. 20, 2019)02/20/2019
Court granted in part and denied in part the motion to dismiss, which raised five issues, including whether the FAA’s 90-day statute of limitations bars the claim to vacate the arbitration award. Court noted that it was uncertain whether § 12 of the FAA applied where a party is claiming that there was no arbitration agreement in the first place, and that defendant had not convinced the court to dismiss plaintiff’s claim based solely on the limitations period. As such, court concluded that it would not, at that time, dismiss plaintiff’s claim based on the 90-day statute of limitations under § 12.
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Smith v. SMX, LLC, No. 3:18-CV-01903-JD (N.D. Cal. Feb. 20, 2019)02/20/2019
Court denied plaintiff’s motion to compel arbitration, holding that plaintiff knew or should have known about the arbitration clause, yet continued to actively litigate her claims for a long time and failed to demonstrate any reason why she should be allowed to renounce her election to prosecute her claims in court and not in arbitration. Court also found the delay prejudicial to the defendant.
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Local 2110, Technical, Office and Professional Union, UAW, AFL-CIO v. Teachers College, Columbia University, No. 1:17-CV-03095-WHP (S.D.N.Y. Feb. 19, 2019)02/19/2019
Court denied the motion to confirm the arbitration award, finding that although there was no dispute about whether the award should be confirmed, there was a dispute over the interpretation of the award and that it would be a “fool’s errand” to confirm an award that is ambiguous.
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Sterling Equipment, Inc. v. St. John’s Ship Building, Inc., No. 3:18-CV-00504-MMH-MCR (M.D. Fla. Feb. 19, 2019)02/19/2019
Court adopted the report and recommendation of the magistrate judge and granted in part and denied in part petitioner’s motion for default judgment and confirmation of arbitration award. Magistrate judge concluded that respondent failed to respond to the instant motion, the time for filing a response had long passed, and it did not appear that the award had been or should be vacated, modified, or corrected. However, post-judgment interest should be from the date of entry of the judgment rather than from the date of the award as the arbitrator concluded.
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Cuker v. Berezofsky, No. 2:18-CV-02356-MAK (E.D. Pa. Feb. 19, 2019)02/19/2019
Court granted Ms. Berezofsky’s motion to confirm the final arbitration award. Court concluded that (i) the panel did not deprive Mr. Cuker of a fair hearing by ruling on the dispositive motions without affording him a right to take discovery, as summary disposition of claims are allowed in arbitration and Mr. Cuker agreed to the discovery procedures; (ii) Mr. Cuker had full opportunity to fully brief and argue his motion for summary disposition; and (iii) the final arbitration award was not in manifest disregard of contract law.
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In re Application of Hulley Enterprises, Ltd., No. 1:18-MC-00435-GBD-GWG (S.D.N.Y. Feb. 19, 2019)02/19/2019
Court denied petitioner’s application for leave to serve subpoenas on respondents, seeking evidence in connection with the litigation currently pending in the Court of Appeal of the Hague. Applying the factors from Intel Corp. v. Advanced Micro Devices, Inc., 542 U.S. 241 (2004), court found that (i) the first Intel factor supported the production of documents generated at the time of respondents’ representation in the 1998-2004 time period because respondents are not a participant in the Dutch proceedings; (ii) the second factor also weighed in favor of production, as petitioner provided examples of cases where the submission of evidence collected through 28 USC § 1782 was admitted; and (iii) there is no exhaustion requirement under §1782 that required petitioners to seek the documents through proceedings in the Netherlands and Russia. However, court also found that petitioner’s delay disfavored a grant of their §1782 application, and additional considerations under the fourth Intel factor more strongly counseled against granting the application.
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Thompson v. Ford of Augusta, Inc., No. 2:18-CV-02512-JAR-KGG (D. Kan. Feb. 15, 2019)02/15/2019
Court, upon construing the defendant’s motion to dismiss for lack of subject matter jurisdiction as a motion to compel arbitration, granted the latter. Court rejected argument that the defendant lost the right to compel arbitration by failing to pay AAA fees and forcing the plaintiff into small claims court. Court further held that any inconsistency between the agreement and AAA rules R-9 did not render the agreement invalid.
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McDonald v. Halliburton, No. 2:18-CV-00585-EAS-CMV (S.D. Ohio Feb. 15, 2019)02/15/2019
Court granted defendant’s motion to compel arbitration and dismissed the action. Analyzing plaintiff’s unconscionability claims under Ohio law, court found that plaintiff failed to establish that any of the terms were substantively unconscionable.
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Taylor v. Comcast’s Corporate Executive Directors, No. 2:18-CV-01230-PJP-RCM (W.D. Pa. Feb. 15, 2019)02/15/2019
Court adopted the report and recommendation of the magistrate judge and granted defendant’s motion to compel arbitration and stay proceedings. The magistrate judge concluded that plaintiff’s claims fell within the definition of “dispute” as set forth in the Subscriber Agreement. This, combined with plaintiff’s failure to opt out of the arbitration agreement suggested that the complaint does not provide a legal basis for rejecting defendant’s affirmative defense of arbitration.
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Swift Financial, LLC v. Alabar Construction, Inc., No. 2:18-CV-02009-SU (D. Or. Feb. 15, 2019)02/15/2019
Court adopted magistrate judge’s findings and recommendation to confirm the arbitration award. Applying the seven factors articulated in Eitel v. McCool, 78 F.2d 1470 (9th Cir. 1986), magistrate judge found that six of the Eitel factors favored entry of default judgment.
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Trustees of Northeast Carpenters Health, Pension, Annuity, Apprenticeship and Labor Management Cooperation Funds v. The Espinosa Group, Inc., No. 2:17-CV-03257-DRH-GRB (E.D.N.Y. Feb. 14, 2019)02/14/2019
Court granted unanswered petition to confirm arbitral award. Court also granted interest and attorneys’ fees.
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Hamilton v. Navient Solutions, LLC, No. 1:18-CV-05432-PAC (S.D.N.Y. Feb. 14, 2019)02/14/2019
Court granted motion to compel AAA arbitration award and denied cross motion to vacate same. Court held that the petition to vacate the award was improper as it was filed one day after the three-month limitations period contained in the FAA. Court further held that, in any case, none of the petitioner’s arguments for vacatur held any merit.
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Zhang v. UnitedHealth Group, No. 0:18-CV-01454-MJD-KMM (D. Minn. Feb. 14, 2019)02/14/2019
Court granted motion to compel arbitration. Court rejected argument that the agreement was illusory because it allowed the defendant-employer to unilaterally modify or terminate the underlying policy. Court likewise declined to hold that the agreement was unconscionable based on the plaintiff’s assertion that he had been in an unequal bargaining position when accepting the agreement, that he was not provided with a copy of the AAA Rules, that the defendant was allowed to unilaterally modify the underlying policy, and that the agreement limited discovery.
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Dornaus v. Best Buy Co., Inc., No. 4:18-CV-04085-PJH (N.D. Cal. Feb. 14, 2019)02/14/2019
Court granted motion to compel arbitration and stayed proceedings, holding that a valid arbitration agreement governed the parties’ dispute. Court agreed with the plaintiff that a provision of the agreement prohibiting adjudication of claims for public injunctive relief was invalid under California law, but held that it could be severed from the rest of the agreement, such that the court would retain jurisdiction over adjudicating any such requests and compel arbitration with respect to any other claims.
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Abeona Therapeutics, Inc. v. EB Research Partnership, Inc., No. 1:18-CV-10889-DLC (S.D.N.Y. Feb. 14, 2019)02/14/2019
Court granted motion to compel arbitration, holding the parties’ agreement contained a broad arbitration clause and the plaintiff’s challenge to the validity of the overall agreement was irrelevant to the motion to compel. Court further held that, in any event, even if the plaintiff’s argument that the agreement lacked consideration could be directed at its arbitration clause, it would fail.
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Crystallex International Corp. v. Bolivarian Republic of Venezuela, No. 17-7068 (D.C. Cir. Feb. 14, 2019)02/14/2019
Court of appeals affirmed district court judgment affirming an arbitral award against a sovereign state. Court held that none of the three arguments asserted “comes close to securing a withdrawal,” reasoning that the district court had sufficiently considered all of the defendant’s arguments under the FAA, appropriately reviewed the arbitral tribunal’s method for calculating damages, and committed no errors in analyzing the award. Court further sanctioned the defendant for conduct it viewed as misleading to the court.
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Ytech 180 Units Miami Beach Investments LLC v. Certain Underwriters At Lloyd's, London, No. 1:18-CV-24770-DLG (S.D. Fla. Feb. 13, 2019)02/13/2019
Court granted motion to compel arbitration and dismissed proceedings. Court rejected argument that purported ambiguity in the structure of the parties’ agreement meant there was no written agreement to arbitrate. Court further held that the parties had agreed to delegate to the arbitrator questions of arbitrability.
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E. Hedinger AG v. Brainwave Science, LLC, No. 1:18-CV-00538-MN (D. Del. Feb. 13, 2019)02/13/2019
Court granted motion to dismiss and compel arbitration. Court rejected arguments that an oral exchange at a hearing constituted waiver of the defendants’ right to arbitrate or that the claims at issue were outside the scope of the arbitral agreement. Court further held that the parties had evidenced an intention to arbitrate even though their agreement referenced a non-existent arbitral institution.
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First Capital Real Estate Investments, L.L.C. v. SDDCO Brokerage Advisors, LLC, No. 1:18-CV-02013-JGK (S.D.N.Y. Feb. 13, 2019)02/13/2019
Court denied motion to vacate FINRA arbitral award and granted cross-motion to confirm and award reasonable attorneys’ fees and prejudgment interest. Court rejected arguments that the award could be vacated because the proceedings were conducted in accordance with rules for intra-industry disputes, that one of the arbitrators was allegedly not qualified, and that the panel imposed discovery sanctions improperly.