TERENCE M. HAIGNEY VS. U-HAUL CO. OF NEW JERSEY, INC.,ET AL.(L-3542-14, MONMOUTH COUNTY AND STATEWIDE), A-4692-14T3

Plaintiff Terence Haigney, a fencing contractor, rented an open trailer from U-Haul, had U-Haul employee Thomas Bia attach it, loaded twenty 80-lb cement bags, and later crashed when the trailer detached, causing Haigney severe permanent injuries.
Haigney sued U-Haul alleging multiple negligence theories: defective ball clamp, inoperable trailer brakes (no brake fluid), and improper attachment by U-Haul employee; arbitration was compelled under an FAA-governed agreement.
At arbitration, testimony from U-Haul employees and experts described proper coupling procedures and acknowledged that an improperly tightened ball clamp/coupler could separate and cause a crash; Haigney and a witness testified the load was evenly distributed.
The arbitrator (retired Judge Corodemus) found U-Haul liable for allowing inoperable brakes and failing to properly attach the trailer; she apportioned liability 80% to U-Haul and 20% to Haigney and awarded damages.
U-Haul sought vacatur in Law Division, arguing the arbitrator exceeded authority by deciding liability on an "improper attachment" theory not pled or supported and abused discretion by refusing U-Haul's rebuttal photographs; the trial court confirmed the award.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the arbitrator exceeded authority by finding liability based on an "improper attachment" theory	Haigney argued negligence broadly (maintenance/inspection/operation) and that discovery and hearing evidence put U-Haul on notice of improper attachment	U-Haul argued the arbitrator decided liability on an unpled theory, without notice, and with no expert or lay support, so the award should be vacated	Court held arbitrator acted within authority; improper attachment was encompassed by negligence claims and was raised in discovery and at hearing, so no excess of power or manifest disregard
Whether arbitrator misconduct or denial of due process occurred by excluding U-Haul's rebuttal photographs/tests	Haigney contended he consistently testified he loaded the trailer evenly and had adequate opportunity to present evidence; exclusion was discretionary under AAA rules	U-Haul argued exclusion denied the chance to rebut alleged inconsistency and deprived it of a fair hearing under 9 U.S.C. § 10(a)(3)	Court held exclusion was within arbitrator's discretion (AAA R-34), U-Haul had ample opportunity to present and cross-examine, and exclusion did not deny a fundamentally fair hearing

Minkowitz v. Israeli, 433 N.J. Super. 111 (App. Div. 2013) (standard of review for arbitration awards and deference to arbitrator under controlling statute)
Manger v. Manger, 417 N.J. Super. 370 (App. Div. 2010) (arbitration review principles)
Metromedia Energy, Inc. v. Enserch Energy Servs., 409 F.3d 574 (3d Cir.) ("extremely deferential" review of arbitration awards under FAA)
Hall Street Assocs. v. Mattel, 552 U.S. 576 (U.S. 2008) (limits on judicial vacatur grounds under FAA)
Tempo Shain Corp. v. Bertek, 120 F.3d 16 (2d Cir.) (arbitrator must provide adequate opportunity to present evidence)