Standard Security Life Ins. Co. of New York v. FCE Benefit Administrators, Inc.

Dist. Ct. did not err in confirming $5.3 million arbitration award that resulted from finding that defendant had breached agreement to serve as third-party administrator of health-care policies issued by plaintiffs. Record also showed that arbitrator issued subsequent finding that rejected other claims submitted by parties and included statement that "all other claims for relief by the parties are denied.” Dist. Ct. could properly conclude that said statement did not cover initial $5.3 million award, since arbitrator made clear that $5.3 award was separate matter. Also, arbitrator could properly resolve indemnification claims, where defendant failed to invoke clause in agreement that allowed defendant to litigate said issues in federal or state court. Moreover, arbitrator could properly consider whether defendant took excessive administrative fees from plaintiffs, even though arbitrator labeled said claim as “embezzlement.”