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Cambridge Legacy Group, Inc. v. Ravi Jain
2013 Tex. App. LEXIS 9017
| Tex. App. | 2013
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Background

  • Cambridge and Jain entered multiple agreements in 2002–2005 governing investment programs, including the option income agreement and two addenda, plus a solicitor agreement with CLA; Cambridge affiliates were involved but not always parties to arbitration.
  • In November 2006 Cambridge terminated Jain’s investment programs, Jain demanded fees and buyouts, and Cambridge refused, leading Jain to sue for breach of contract and related claims.
  • The parties moved to compel FINRA arbitration in February 2008; FINRA arbitration proceeded with three arbitrators in February–March 2012.
  • On March 5, 2012 the FINRA panel awarded Jain $41,600 in compensatory damages and $42,000 in attorneys’ fees; JPMorgan? (text shows Jain) remains the prevailing party.
  • Cambridge moved to vacate; Jain moved to confirm; the trial court denied vacatur, confirmed the award, and entered final judgment in Jain’s favor on April 24, 2012.
  • Cambridge pursued a direct appeal challenging the confirmation, raising the arbitrators’ powers and scope as the core issues.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Did the arbitrators exceed their powers? Cambridge Jain No; panel acted within the scope and did not exceed authority
Did Cambridge waive judicial review of the arbitration award? Cambridge Jain No waiver; FINRA submission silent on review, and rule 13904 does not waive review

Key Cases Cited

  • Prudential Sec. Inc. v. Marshall, 909 S.W.2d 896 (Tex. 1995) (arbitration review favored; limited grounds for vacatur)
  • Skidmore Energy, Inc. v. Maxus (U.S.) Exploration Co., 345 S.W.3d 672 (Tex. App.—Dallas 2011) (deference to arbitrator’s decision; limited review)
  • Centex/Vestal v. Friendship West Baptist Church, 314 S.W.3d 677 (Tex. App.—Dallas 2010) (scope of arbitrable issues; broad arbitration clause)
  • Ancor Holdings, LLC v. Peterson, Goldman & Villani, Inc., 294 S.W.3d 818 (Tex. App.—Dallas 2009) (presumption in favor of arbitration; limited review)
  • Royce Homes, L.P. v. Bates, 315 S.W.3d 77 (Tex. App.—Houston [1st Dist.] 2010) (limits of vacatur; not easily overturned for error)
  • Townes Telecomms., Inc. v. Travis, Wolff & Co., L.L.P., 291 S.W.3d 490 (Tex. App.—Dallas 2009) (arbitration scope and deference to panel decisions)
  • NAFTA Traders, Inc. v. Quinn, 339 S.W.3d 84 (Tex. 2011) (contractual limits on arbitration and judicial review)
  • In re Chestnut Energy Partners, Inc., 300 S.W.3d 386 (Tex. App.—Dallas 2009) (burden to vacate rests with party seeking vacatur)
Read the full case

Case Details

Case Name: Cambridge Legacy Group, Inc. v. Ravi Jain
Court Name: Court of Appeals of Texas
Date Published: Jul 22, 2013
Citation: 2013 Tex. App. LEXIS 9017
Docket Number: 05-12-00991-CV
Court Abbreviation: Tex. App.