Supreme Court of Alabama

Raymond James Financial Services, Inc., and Bernard Michaud v. Kathryn L. Honea

June 18, 20102010 Ala. LEXIS 99

Summary

The court held that, although federal law makes its statutory grounds for vacating an arbitration award exclusive in proceedings governed by that statute, Alabama state law may enforce a contractual provision providing for broader judicial review. The agreement therefore required a de novo review of the arbitration transcript and exhibits, but the trial court erred by vacating the award and ordering a new trial without conducting that review. The judgment was reversed and remanded for the contractually required review. Justice Murdock, concurring specially, agreed with the disposition and additionally concluded that any objection to the arbitration panel's composition had been waived.