In Murillo v. A Better Way Wholesale Autos & Westlake Servs., Llc, No. 3:17-CV-1883 (VLB), 2019 U.S. Dist. LEXIS 117043 (D. Conn. July 15, 2019), Judge Bryant confirmed a runaway arbitration award against a car dealer. The parties agreed to arbitrate their disputes before the American Dispute Resolution Center (“ADR”) as a desk arbitration and under the American Arbitration Association (“AAA”) rules. Both sides made submissions to the arbitrator, following multiple missed deadlines by Defendants, and the arbitrator considered the claims on the merits.
This Court acknowledges that the arbitrator’s award of punitive damages in this case at twenty-five times the actual and statutory damages, for a total of $234,708.50 in punitive damages, is significant. But even if this Court believed that such an award would constitute an abuse of discretion if imposed by a court, such a standard is not applicable on review of an arbitration decision. See Westerbeke, 304 F.3d at 208. The question here is not whether the arbitrator abused his discretion or even erred in his application of the law, but whether he knowingly chose to disregard clearly established law. Defendants have failed to show that the arbitrator so manifestly disregarded any law in setting the award.