Weeden Construction v. Simbeck, 514 P.3d 401

Weeden (general contractor) subcontracted with Simbeck to install geosynthetic lining at a mine; the Subcontract had no fixed completion deadline and work was delayed into winter.
Concerned about pace, Weeden hired H2J to perform the same lining work without informing Simbeck; Simbeck removed its crews and equipment and Weeden terminated the Subcontract for default.
Simbeck demanded arbitration under the Subcontract; the parties agreed the arbitrator would issue a "reasoned award." After a merits hearing the arbitrator issued an Interim Award finding Weeden materially breached by hiring H2J and later a Final Award including damages and attorney fees (total ≈ $597,778).
Weeden petitioned the district court to vacate the awards; the district court vacated both awards, concluding the arbitrator applied a subjective standard to material breach and failed to issue a proper reasoned opinion, and ordered a new arbitration.
On appeal the Montana Supreme Court reviewed whether the district court abused its limited authority under the MUAA and whether Simbeck was entitled to attorney fees for litigating to enforce the award under the Prompt Payment Act.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the district court err by vacating the arbitrator's award and ordering new arbitration?	Weeden: The Arbitrator exceeded authority by issuing an award that lacked a reasoned opinion, applied a subjective standard to material breach, and thus vacatur was proper.	Simbeck: The Arbitrator issued the parties‑requested "reasoned award," made ultimate objective findings that Weeden hired H2J to perform a material portion of the subcontract, and courts must defer under the MUAA.	Reversed. The Interim Award met the "reasoned award" form and contained ultimate objective findings of material breach; district court abused its discretion in vacating under the MUAA.
Is Simbeck entitled to attorney fees for litigation enforcing the arbitration award in court and on appeal?	Simbeck: Prevailing party on enforcement is entitled to reasonable attorney fees under the Prompt Payment Act (§ 28-2-2105, MCA).	Weeden: MUAA does not authorize court-awarded fees; arbitrator’s fee award was grounded in parties' arbitration agreement and AAA rules, not the MUAA.	Held for Simbeck. Prompt Payment Act applies to actions to enforce obligations under the Act; Simbeck may recover reasonable fees and costs incurred defending the award in court and on appeal—remanded to quantify fees.

Sutey Oil Co. v. Monroe's High Country Travel Plaza, L.L.C., 506 P.3d 310 (Mont. 2022) (explains MUAA imposes strict, limited judicial review of arbitration awards)
City of Livingston v. Montana Public Employees Ass'n ex rel. Tubaugh, 339 P.3d 41 (Mont. 2014) (courts defer to arbitrator so long as award derives its essence from the contract)
Tedesco v. Home Savings Bancorp, Inc., 407 P.3d 289 (Mont. 2017) (standard of review for district court decisions on arbitration awards)
Terra W. Townhomes, L.L.C. v. Stu Henkel Realty, 996 P.2d 866 (Mont. 2000) (arbitrator's blatant refusal to follow clearly governing law can justify vacatur)
Nelson v. Livingston Rebuild Ctr., Inc., 981 P.2d 1185 (Mont. 1999) (arbitrators exceed powers when deciding matters beyond scope submitted)
Dick Anderson Construction, Inc. v. Monroe Construction Co., L.L.C., 221 P.3d 675 (Mont. 2009) (Prompt Payment Act fees may apply to litigation enforcing arbitration awards; reasonableness inquiry required)
Gunnerson v. Stage Stores, Inc., 477 S.W.3d 848 (Tex. App. 2015) (discussion of what constitutes a "reasoned award"—more than result but less than full findings and conclusions)
Ferdig Oil Co. v. ROC Gathering, L.L.P., 432 P.3d 118 (Mont. 2018) (material breach is a question of fact and courts defer to arbitrator's factual determinations)