The Southern District of New York remanded an arbitration award back to the arbitrator for clarification, as the parties had agreed to a “reasoned” award, and the arbitrator exceeded his authority in issuing an award that did not meet the standard of a reasoned opinion. In dismissing the petitioner’s arguments, the court noted that “the arbitrator conclusorily states that ‘having heard all of the testimony, reviewed all of the documentary proofs and exhibits, he does not find support for [the petitioner’s] claims.’ … There is no reason given for this finding other than the negative credibility determination as to [the petitioner’s] expert witness.” New York precedent states: “[A]n arbitrator exceeds his or her powers when the arbitrator renders a form of award that does not satisfy the requirements the parties stipulated to in their arbitration agreement.”

Smarter Tools, Inc v Chongqing SENCI Import & Export Trade Co., 1:18-cv-02714 (S.D.N.Y. Mar. 26, 2019)