Samaan v. General Dynamics Land Systems, Inc.
835 F.3d 593
| 6th Cir. | 2016Background
- Samaan, a long‑time engineer at General Dynamics, alleged the company used improper shock‑and‑vibration testing on Stryker vehicles and submitted false reports to the Army. He raised internal complaints and later reported concerns to an Army liaison.
- After Samaan informed General Dynamics that he had spoken with the Army, the Company suspended him without pay pending an investigation; he resigned after learning HR would recommend termination.
- Samaan sued in federal court asserting (in various iterations) False Claims Act relator and retaliation claims, Michigan whistleblower and public‑policy claims, and age discrimination. He removed the FCA relator claim before arbitration.
- The parties agreed to arbitrate; the arbitration agreement permitted dispositive motions and provided that an "award shall be made no later than 30 days from the date of the closing of the hearing." General Dynamics moved for summary disposition.
- The arbitrator (Judge Rashid) held a short hearing (unrecorded), later granted General Dynamics’ summary‑disposition motion, and dismissed all claims with prejudice. Samaan moved in district court to vacate the award under the FAA; the court denied the motion.
- The Sixth Circuit affirmed, holding Samaan failed to establish any statutory ground for vacatur under 9 U.S.C. § 10(a).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether arbitrator’s failure to issue award within 30 days of motion hearing required vacatur under §10(a)(4) | The Agreement’s §16 30‑day deadline began at the closing of the motion hearing; delay to issuance (May 2015) exceeded arbitrator’s powers | The 30‑day limit applies to a trial‑like arbitration hearing (not a dispositive‑motion hearing); other contract provisions permit the arbitrator to manage motions and deadlines | Held for defendant: contractual language read as whole limits 30‑day clock to trial‑like hearings; delay alone did not exceed powers |
| Whether alleged arbitrator partiality/misconduct (remarks, urging settlement, not reading briefs) required vacatur under §10(a)(2)–(3) | Arbitrator made biased remarks, admitted not reading Samaan’s briefs, said case was too complicated, urged settlement—showing evident partiality/misbehavior | No transcript or sworn evidence supports Samaan’s unsworn assertions; defendant contests the claims | Held for defendant: plaintiff failed to produce evidentiary support; unsubstantiated, self‑serving allegations insufficient for vacatur |
| Whether failure to hold evidentiary hearing violated §10(a)(3) (refusal to hear evidence) | Samaan lacked opportunity to present witnesses/evidence at an evidentiary hearing | Agreement expressly allowed arbitrator to order a hearing on dispositive motions “as the Arbitrator deems necessary”; no absolute right to an evidentiary hearing in arbitration | Held for defendant: no authority requires an evidentiary hearing; parties contracted for motion procedure; absence of hearing not FAA vacatur ground |
| Whether incorporation of opposing party’s brief language or failure to address every argument warrants vacatur under §10(a)(2)–(4) | Award copied General Dynamics’ brief verbatim and omitted discussion of some Samaan arguments, showing bias or imperfect execution | Courts/arbitrators may incorporate party submissions; failure to address every argument is not statutory misconduct and legal error alone is not basis for vacatur | Held for defendant: incorporation or omission does not meet §10 vacatur standards; legal errors insufficient for vacatur |
Key Cases Cited
- Merrill Lynch, Pierce, Fenner & Smith, Inc. v. Jaros, 70 F.3d 418 (6th Cir. 1995) (standards for vacatur and manifest‑disregard doctrine discussion)
- First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938 (1995) (standard of review for arbitrator fact findings and legal questions)
- Hall Street Assocs., L.L.C. v. Mattel, Inc., 552 U.S. 576 (2008) (statutory §10(a) grounds are exclusive for FAA vacatur)
- Stolt‑Nielsen S.A. v. AnimalFeeds Int’l Corp., 559 U.S. 662 (2010) (limits on vacatur and discussion of manifest‑disregard question)
- Uhl v. Komatsu Forklift Co., Ltd., 512 F.3d 294 (6th Cir. 2008) (narrow review of arbitrator decisions; burden to show partiality)
- Solvay Pharm., Inc. v. Duramed Pharm., Inc., 442 F.3d 471 (6th Cir. 2006) (courts must refrain from vacating awards for mere legal/factual error)
- Bratt Enters., Inc. v. Noble Int’l Ltd., 338 F.3d 609 (6th Cir. 2003) (federal policy favoring arbitration and FAA framework)
- Volt Info. Scis., Inc. v. Bd. of Trs. of Leland Stanford Jr. Univ., 489 U.S. 468 (1989) (state contract principles apply to arbitration agreement interpretation)
- Grain v. Trinity Health, Mercy Health Servs. Inc., 551 F.3d 374 (6th Cir. 2008) (post‑Hall Street treatment of manifest‑disregard issue)
- Kilburn v. United States, 938 F.2d 666 (6th Cir. 1991) (permissibility of incorporating party submissions into judicial orders)