Central Montana Rail v. Bnsf Railway Company
422 F. App'x 636
9th Cir.2011Background
- CMR appeals district court’s confirmation of an arbitration award, denial of dismissal without prejudice, and grant of summary judgment for BNSF.
- FAA requires courts to confirm arbitration awards unless vacated, modified, or corrected under specified grounds.
- The district court held the arbitrators acted within their scope and did not manifestly disregard the law.
- CMR sought dismissal without prejudice under Rule 41(a)(2); the court weighed potential legal prejudice and forum considerations.
- The district court granted summary judgment against CMR, finding Settlement Agreement barred third-party recovery and Montana contract-law limits on damages applied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the FAA requires vacatur or reversal of the arbitration award. | CMR contends vacatur due to error exceeding authority and manifest disregard. | BNSF argues deferential review; no excess of authority or manifest disregard. | Vacatur not warranted; arbitration within scope and no manifest disregard. |
| Whether dismissal without prejudice was appropriate under Rule 41(a)(2). | CMR seeks dismissal without prejudice to avoid adverse forum outcomes. | BNSF asserts district court properly weighed prejudice and forum shopping. | Court did not abuse discretion; no plain legal prejudice and forum-shopping concern supported denial. |
| Whether summary judgment was proper on damages and contract interpretation. | CMR claims damages were available under Settlement Agreement or Montana law. | BNSF argues terms forbid third-party recovery and Montana law bars claimed damages. | Summary judgment proper; no genuine issues of material fact and law supports denial. |
Key Cases Cited
- Hall St. Assocs., L.L.C. v. Mattel, Inc., 552 U.S. 576 (U.S. Supreme Court 2008) (vacatur and modification procedures under FAA; close standard of review)
- Mich. Mut. Ins. Co. v. Unigard Sec. Ins. Co., 44 F.3d 826 (9th Cir. 1995) (arbitration award review; limits on vacatur for error)
- PowerAgent Inc. v. Elec. Data Sys. Corp., 358 F.3d 1187 (9th Cir. 2004) (limited, deferential review of arbitration awards)
- Westlands Water Dist. v. United States, 100 F.3d 94 (9th Cir. 1996) (analysis of legal prejudice in voluntary dismissal)
- Kern Oil & Refining Co. v. Tenneco Oil Co., 792 F.2d 1380 (9th Cir. 1986) (forum shopping in dismissal decisions)
- Collins v. D.R. Horton, Inc., 505 F.3d 874 (9th Cir. 2007) (reiterates deferential standards in review of arbitration and related motions)