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