Sentient Lasers, LLC v. Ronald DeMeo
The Third DCA reversed a trial court order vacating an arbitration award, holding the arbitrator did not exceed his authority in finding Dr. DeMeo personally liable and in deciding the arbitrability of a related civil theft dispute over a second laser machine. Applying Utah law under the contracts' choice-of-law clause, the court held the trial court impermissibly made its own findings of fact and substituted its judgment for the arbitrator's under Utah's 'irrationality principle.'
Key facts
- Sentient Lasers, LLC sued Ronald DeMeo over arbitration awards concerning a laser machine contract and related equipment dispute, with the contract containing a Utah choice-of-law clause and a delegation clause giving the arbitrator authority over arbitrability questions.
- The trial court vacated the arbitration award, finding the arbitrator exceeded his authority by holding Dr. DeMeo personally liable and by deciding the arbitrability of a related civil theft claim involving a second laser machine.
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Why it matters
A useful decision for arbitration practitioners on two fronts: it enforces a delegation clause giving the arbitrator exclusive authority over substantive and procedural arbitrability, and it emphasizes that a court… — full analysis with a trial
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