S. Ct. Civ. No. 2016-0105

A Superior Court order confirming an arbitration award requiring the Virgin Islands Department of Education to pay attorney's fees to the St. Thomas/St. John Educational Administrators Association is affirmed for the reasons stated in this opinion. Since § 10 of the Federal Arbitration Act does not preempt local law in proceedings instituted in local courts, and the collective bargaining agreement in this case does not explicitly contract for application of § 10, local law must be applied to determine the circumstances under which a court may vacate or modify an arbitration award. Because arbitration in the Virgin Islands is not governed by statute, approaches taken by courts in this jurisdiction and other jurisdictions are reviewed to determine the soundest rule of law for this jurisdiction. Arbitration is a matter of contract, and courts should strive to most appropriately implement the intent of the parties. To ensure that parties who bargain for binding arbitration receive the benefit of their bargain, the Superior Court may only vacate an arbitrator's award if: (1) the arbitrator exceeded his or her authority in rendering the award (which may include ignoring limits in the arbitration agreement itself on issues to be arbitrated or remedies the parties agreed to make available); (2) if the award was the product of fraud, partiality, or malfeasance on behalf of the parties or the arbitrator—or if the award was predicated upon a mistake flowing from such conduct; or (3) if the arbitrator manifestly disregards the law. The fact that a party—or a reviewing court—disagrees with how an arbitrator interprets a contract is not sufficient grounds to vacate the decision, and an arbitrator's interpretation of an undefined term does not constitute a manifest disregard of the contractual provisions of the collective bargaining agreement, or of the applicable law. Thus applying the applicable standards in the present case there is no basis for vacating the arbitrator's award. The Superior Court erred when it rejected the arbitrator's interpretation of the collective bargaining agreement, but it nevertheless reached the correct result by confirming the award. The October 26, 2016 order upholding the arbitrator's fee award is affirmed, albeit for reasons different from those stated by the Superior Court.