Leviathan Group LLC v. Delco LLC
24-1547
6th Cir.Mar 21, 2025Background
- Leviathan Group LLC and Delco LLC entered into a marketing contract with a $100,000 monthly fee, including an arbitration clause for dispute resolution.
- Disputes over performance and payments arose in 2021, leading both parties to arbitration under the American Arbitration Association.
- The arbitrator found for Leviathan, determining Delco breached the contract, awarding damages and attorney's fees to Leviathan, and disposing of all claims.
- Leviathan requested state court confirmation of the award; Delco removed to federal court and sought to vacate or modify the award.
- The district court confirmed the award, ruling none of the statutory grounds for vacatur under the Federal Arbitration Act were present; Delco appealed.
Issues
| Issue | Leviathan's Argument | Delco's Argument | Held |
|---|---|---|---|
| Award Confirmation | Arbitration award should be confirmed | Arbitrator's final award ignored earlier relief | Final award superseded any prior relief |
| Attorney’s Fees | Fees properly awarded under contract | Michigan law requires more evidence for fees | Arbitrator acted within her authority |
| Arbitral Authority & Fairness | Arbitrator decided contract disputes | Award was one-sided, outside contract’s essence | Arbitrator was within her authority |
Key Cases Cited
- Uhl v. Komatsu Forklift Co., Ltd., 512 F.3d 294 (6th Cir. 2008) (arbitration awards are presumed to be confirmed)
- Mich. Fam. Res., Inc. v. Serv. Emp. Int’l Union Local 517M, 475 F.3d 746 (6th Cir. 2007) (vacatur only if arbitrator exceeded authority, acted with dishonesty, or ignored contract)
- Green v. Ameritech Corp., 200 F.3d 967 (6th Cir. 2000) (arbitrator not required to provide detailed reasoning unless contract states)