HIALEAH PARK, INC. APPELLANT,
v.
OCALA BREEDERS' SALES COMPANY, APPELLEE
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Hialeah Park appeals a circuit court order confirming a $725,000 arbitration award, arguing the award bears no rational relationship to the damages evidence presented. The court affirmed, holding that arbitration awards need not coincide with a party's damages request and courts may not substitute their judgment for arbitrators' on disputed factual issues.
An arbitration award need not coincide with a party's request for damages. A court will not vacate or remand an arbitration award where the award falls within the range of evidence presented, is within the scope of submission to arbitration, and shows no clear evidence of arbitrator improprieties under Florida law.
[1] An arbitration award is not required to coincide with a party's requested damages.
[2] Arbitrators are not required to disclose the precise mathematical basis for their damages award.
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“we are unaware of any legal requirement that an arbitration award must coincide with a party's request for damages, and the appellant Hialeah Park, Inc. cites none”
Establishes the core holding that arbitration awards need not match a party's stated damage calculation.
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Join FLexlaw to unlock all legal intelligenceHialeah Park and Ocala Breeders' Sales Company were parties to a lease dispute that went to arbitration for breach of contract. The arbitrators awarde…
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PER CURIAM.
Hialeah Park, Inc. appeals from a circuit court order confirming an adverse arbitration award in a breach of contract action involving a lease. The sole point on appeal is that the $725,000 award “bears no rational relationship to the evidence that the parties presented with respect to damages,” in that the award “fails to coincide with the amount of damages requested by [the appellee Ocala Breeders’ Sales Co.] with respect to any of its claims or combination of claims or a set-off of Hialeah Park’s claim against [the appellee’s] claims.” Initial Brief of Appellant at 5. This being so, it is urged that the arbitration award “should be referred back to the arbitrators or vacated because the arbitrary nature of the award has precluded meaningful judicial review as required by the Florida Arbitration Code.” Id. at 4; see §§ 682.13, 682.14, Fla.Stat. (1987).
We disagree because, simply stated, we are unaware of any legal requirement that an arbitration award must coincide with a party’s request for damages, and the appellant Hialeah Park, Inc. cites none. Beyond that, the $725,000 award was well within the range of evidence adduced below as to lost profits, out-of-pocket expenses, and interest sought on this unliq-uidated claim; accordingly, the award is unassailable under Sections 682.13, 682.14, Florida Statutes (1987).
It is well settled that arbitrators are not required to disclose the precise mathematical basis upon which they arrived at a damages award, Koch Oil, S.A. v. Transocean Gulf Oil Co., 751 F. 2d 551 (2d Cir.1985); see Prudential-Bache Secs., Inc. v. Shuman, 483 So. 2d 888 (Fla. 3d DCA 1986); Weeki Wachee Orchid Gardens, Inc. v. Florida Inland Theatres, Inc., 239 So. 2d 602, 603 (Fla. 2d DCA 1970), cert. denied, 246 So. 2d 110 (Fla.1971), and that a court will not substitute its judgment for that of the arbitrators, or review awards entered on disputed issues of fact, where, as here, the award could have been entered on the evidence presented, was within the scope of the submission to arbitration, and where, as here, there is no clear showing that the award is the result of the arbitrator improprieties listed in Section 682.13(1), Florida Statutes (1987).
Merritt-Chapman & Scott Corp. v. State Road Dept., 98 So. 2d 85, 86 (Fla.1957); Ogden v. Baile, 73 Fla. 1103, 1115, 75 So. 794, 797 (1917); Affiliated Mktg., Inc. v. Dyco Chems. & Coatings, Inc., 340 So. 2d 1240, 1243 (Fla. 2d DCA), cert. denied, 353 So. 2d 675 (Fla.1977); Carol City Utils., Inc. v. Gaines Constr. Co., 201 So. 2d 242, 244 (Fla. 3d DCA 1967), cert. denied, 210 So. 2d 221 (Fla.1968); see also A.G. Edwards & Sons, Inc. v. Petrucci, 525 So. 2d 918, 921 (Fla. 2d DCA 1988).
Affirmed.
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Ocala Breeders' Sales Co. v. Brunetti, 567 So. 2d 490 (Fla. 3d DCA 1990)…e of the case. (Emphasis added). The arbitration proceeded between Ocala and Hialeah. An award was entered in Ocala’s favor, which was confirmed by the [*492] trial court and affirmed by this court. Hialeah Park, Inc. v. Ocala Breeders' Sales Co., 528 So. 2d 1227 (Fla. 3d DCA 1988). Ocala then moved to vacate the stay so it could pursue its misrepresentation claim against Brunetti individually. The trial court denied the motion to vacate stay, denied an alternative motion to resubmit the claim against Brune…
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Kintzele v. J.B. & Sons, Inc., 658 So. 2d 130 (Fla. 1st DCA 1995)…Fla.1995). If section 768.73, Florida Statutes (1993) does not apply to arbitration awards of punitive damages, judicially created pleading requirements on the subject must likewise be inapposite. Cf. Hialeah Park, Inc. v. Ocala Breeders’ Sales Co., 528 So. 2d 1227 (Fla. 3d DCA 1988) (“we are unaware of any legal requirement that an arbitration award must coincide with a party’s request for damages”). Appellant’s request for arbitration gave fair notice of the dispute to be arbitrated. Mr. Kintzele alleged th…
Authorities Cited (12 total)
- Ogden v. Baile, 73 Fla. 1103 (Fla. 1917)
- Prudential-Bache Sec., Inc. v. Shuman, 483 So. 2d 888 (Fla. 3d DCA 1986)
- Affiliated Mktg., Inc. v. Dyco Chems. & Coatings, Inc., 340 So. 2d 1240 (Fla. 2d DCA 1976)
- Carol City Utils., Inc. v. Gaines Constr. Co., 201 So. 2d 242 (Fla. 3d DCA 1967)
- Chesapeake House, Inc. v. LEE Mut. Ins. Agency, Inc., 239 So. 2d 602 (Fla. 2d DCA 1970)
- Kuhn v. Telford, 98 So. 2d 85 (Fla. 1957)
- In re the Arb. between Koch OIL, S.A., 751 F.2d 551 (2d Cir. 1985)
- A.G. Edwards & Sons, Inc. v. Petrucci, 525 So. 2d 918 (Fla. 2d DCA 1988)
- Rewis v. State, 210 So. 2d 221 (Fla. 1968)
- Ervin M. Smith, Jr. v. State, 210 So. 2d 221 (Fla. 1968)