Hidroelectrica Santa Rita S.A. v. Corporacion AIC, SA, 119 F.4th 920

Corporación AIC, S.A. (AICSA) and Hidroeléctrica Santa Rita S.A. (HSR), both Guatemalan companies, entered into an EPC Contract for AICSA to build a hydroelectric plant in Guatemala.
Construction was halted due to local community opposition and threats, leading HSR to suspend and later terminate the contract, citing force majeure.
Arbitration was initiated by HSR seeking return of advance payments and other damages; AICSA counterclaimed and sought to join its subcontractor, Novacom, to the proceedings.
The arbitral tribunal ruled partially for both parties, dismissed AICSA’s bribery-based claims, refused to join Novacom, and clarified AICSA must replace expired payment bonds.
AICSA sought to vacate the arbitral award in U.S. court, arguing the tribunal exceeded its authority; the district court confirmed the award, leading to this appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Tribunal's authority to require new Advance Payment Bonds	AICSA: Tribunal exceeded authority by mandating new bonds if originals lapsed	HSR: Tribunal interpreted the contract, as it allowed bonds to be maintained	Tribunal acted within its authority; decision upheld
Tribunal's denial of AICSA's anti-corruption/breach claim	AICSA: Tribunal exceeded authority in denying FCPA-based breach claim	HSR: Tribunal lacked jurisdiction and evidence for a FCPA private action	Tribunal interpreted the contract/FCPA; no excess of authority
Refusal to join Novacom to arbitration	AICSA: Tribunal misinterpreted contract by denying Novacom's joinder	HSR: EPC Contract did not permit third-party asserted claims in arbitration	Tribunal's contract-based interpretation was within authority

Oxford Health Plans LLC v. Sutter, 569 U.S. 564 (arbitrator’s contract interpretation must stand if even arguably based on the contract)
United Paperworkers Int’l Union, AFL-CIO v. Misco, Inc., 484 U.S. 29 (courts cannot vacate arbitration awards for mere legal error; arbitrator must act beyond authority)
Stolt-Nielsen S.A. v. AnimalFeeds Int’l Corp., 559 U.S. 662 (arbitrator exceeds authority only when acting outside the bounds of the contract)
E. Associated Coal Corp. v. United Mine Workers of Am., Dist. 17, 531 U.S. 57 (arbitration awards grounded in contract interpretation are deferred to by courts)
Enter. Wheel & Car Corp., 363 U.S. 593 (finality of arbitral interpretation must be honored by courts)