Casa Del Mar Association, Inc. v. Williams & Thomas, L.P. D/B/A Jamail Construction, 476 S.W.3d 96

Casa del Mar Association contracted Jamail Construction for improvements at a condo complex; disputes arose over alleged defects.
Casa del Mar initiated arbitration seeking damages for breach of contract, breach of express warranty, implied warranty of good and workmanlike conduct, negligence, and negligent misrepresentation.
Arbitration panel issued a reasoned award denying most damages and awarding $24,490.20, with 30% of the broader damage estimate allocated to Jamail and 70% to Casa del Mar; tort claims were denied under the economic loss rule.
Casa del Mar moved to correct the award and then sought to vacate in Texas courts; the panel denied the motion to correct.
The district court denied the motion to vacate and granted the motion to confirm; the appellate court (14th Court) affirmed, holding manifest disregard of the law is not a ground for vacatur and gross-mistake grounds were not proven.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the award can be vacated for gross mistake or manifest disregard	Casa del Mar argues gross mistake and manifest disregard apply	Jamail contends these grounds do not exist under Texas or Federal law	No vacatur on either ground; manifest disregard not a Texas/Federal basis and gross-mistake burden unmet
Whether exhibits attached to the motion to vacate require remand or abatement for proper consideration	Exhibits were missing from the trial court file but should be considered	Exhibits not essential to vacatur decision and record supports denial	No remand or abatement required; record supports denial of vacatur

CVN Group, Inc. v. Delgado, 95 S.W.3d 234 (Tex. 2002) (arbitration award vacatur standards under Texas law; public policy limits)
Action Box Co. v. Panel Prints, Inc., 130 S.W.3d 249 (Tex. App.—Hou. [14th Dist.] 2004) (public policy and standards for vacating under Texas Act)
Kline v. O’Quinn, 874 S.W.2d 776 (Tex. App.—Hou. [14th Dist.] 1994) (arbitration award review in Texas; limits on vacatur grounds)
Callahan & Assocs. v. Orangefield Indep. Sch. Dist., 92 S.W.3d 841 (Tex. 2002) (burden on movant to show gross mistake and bad faith)
Black v. Shor, 443 S.W.3d 154 (Tex. App.—Corpus Christi 2013) (insufficient showing of gross mistake to vacate)
Carpenter v. North River Ins. Co., 436 S.W.2d 549 (Tex. Civ. App.—Hou. [14th Dist.] 1968) (burden to show gross mistake includes bad faith/honest judgment)
Hall Street Assocs., L.L.C. v. Mattel, Inc., 552 U.S. 576 (S. Ct. 2008) (federal grounds for vacatur are exclusive)
Ewing v. ACT Catastrophe-Texas, L.C., 375 S.W.3d 545 (Tex. App.—Houston [14th Dist.] 2012) (manifest disregard not a Texas Act ground for vacatur)
Leslie v. Hill, 2014 WL 5309660 (Tex. App.—Hou. [14th Dist.] 2014) (no published opinion; vacatur standards)
Action Box Co. v. Panel Prints, Inc., 130 S.W.3d 249 (Tex. App.—Hou. [14th Dist.] 2004) (reiterated above; vacatur standards)