Leader Tech. v. MultiNational Resour

2004 DNH 178
CourtDistrict Court, D. New Hampshire
DecidedDecember 3, 2004
DocketCV-01-359-JD
StatusPublished

This text of 2004 DNH 178 (Leader Tech. v. MultiNational Resour) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Leader Tech. v. MultiNational Resour, 2004 DNH 178 (D.N.H. 2004).

Opinion

Leader Tech. v. MultiNational Resour CV-01-359-JD 12/03/04 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Leader Technology Co.

v. Civil No. 01-359-JD Opinion No. 2004 DNH 178 MultiNational Resources, Inc.

O R D E R

Leader Technology Company brought suit in state court

against MultiNational Resources, Inc. ("MNR"), alleging breach of

contract and guantum meruit. MNR then removed the action to this

court based on diversity jurisdiction pursuant to 28 U.S.C. §

1332, and brought several counterclaims. MNR moved to remand the

case for arbitration under the Federal Arbitration Act ("FAA"), 9

U.S.C. § 1, et seg., pursuant to the arbitration clause in the

parties' agreement. The court granted that part of MNR's motion

seeking arbitration. Order, Dec. 19, 2001, (doc. no. 11).

Background

The parties arbitrated their dispute before a three-

arbitrator panel of the American Arbitration Association ("AAA").

On August 16, 2004, the panel issued its decision to award Leader

$495,766.07, and the AAA issued the award on August 24, 2004. On

September 1, 2004, Leader filed a petition to confirm the

arbitration award pursuant to 9 U.S.C. §§ 9 and 9/13" style="color:var(--green);border-bottom:1px solid var(--green-border)">13. MNR objected to the petition on the ground that it intended to file an

application, pursuant to the AAA Rules, to correct computational

errors in the award. The panel denied MNR's application on

September 28, 2004.

MNR then filed a second objection to Leader's motion to

confirm and a motion to stay the proceedings, seeking time to

file a motion to vacate the award. MNR cited the New Hampshire

Arbitration Act, New Hampshire Revised Statutes Annotated ("RSA")

§ 542:8, et seg., as the basis for its planned motion. Leader

objects to MNR's motion to stay the proceedings.

Discussion

Leader asserts that the arbitration panel's award should be

confirmed pursuant to 9 U.S.C. §§ 9 and 9/13" style="color:var(--green);border-bottom:1px solid var(--green-border)">13, asking the court to

enter judgment confirming the award in its favor of $495,776.07.

MNR objects to Leader's motion on the ground that it intends to

file a motion to vacate the award and asks that the proceedings

be stayed until ninety days after September 28, 2004, by which

time MNR intends to file its motion. MNR asserts that New

Hampshire law governs the remaining issues in this case.

2 A. Governing Law

MNR contends that choice-of-law clause in the parties'

agreement directs that New Hampshire law, including the New

Hampshire Arbitration Act, governs the court's review of the

arbitration award. That clause provides that the "Agreement is

made under, and the validity, construction and performance of

this Agreement shall be governed and interpreted in accordance

with, the laws of the State of New Hampshire, United States of

America." Motion for Stay, Ex. A, 5 15 (doc. no. 18) . With

respect to arbitration, however, the same clause provides that

the parties' disputes "shall be finally settled by binding

arbitration to be conducted in the State of New Hampshire in

accordance with the Commercial Arbitration Rules of the American

Arbitration Association."

As is noted above, the parties have proceeded to this point

under the FAA. The court previously held that the FAA governed

the proceedings because the parties' agreement concerns

interstate commerce. Order, Dec. 19, 2001, at 5. MNR did not

challenge that decision and failed to mention it in its present

motion.

Even if this issue had not been resolved previously in this

case, MNR's argument that New Hampshire arbitration law governs

would not succeed. Parties may agree to arbitrate under state

3 law. See, e.g.. Ford v. NYLCare Health Plans of the Gulf Coast,

Inc., 141 F.3d 243, 248-49 (5th Cir. 1998); Ekstrom v. Value

Health, Inc., 68 F.3d 1391, 1395-96 (D.C. Cir. 1995); Int'1

Techs. Integration, Inc. v. Palestine Liberation Org., 66 F.

Supp. 2d 3, 8-10 (D.D.C. 1999). If the parties intend that state

arbitration laws govern their proceedings, however, that intent

must be stated clearly to avoid the presumption that the FAA

governs arbitration. See, e.g., Mastrobuono v. Sherson Lehman

Hutton, Inc., 514 U.S. 52, 63-64 (1995); Roadway Package Sys.,

Inc. v. Kayser, 257 F.3d 287, 294-95 (3d Cir. 2001); Paine Webber

Inc. v. Elahi, 87 F.3d 589, 594 (1st Cir. 1996); Calabria v.

Franklin Templeton Servs., Inc., 2001 WL 1180466, at *3 (N.D.

Cal. Sept. 26, 2001).

In this case, the choice-of-law clause states that the

agreement will be construed under New Hampshire law. At the same

time, however, the clause provides for arbitration under federal

law. Therefore, the FAA, rather than state law, applies to the

court's review of the arbitration proceeding. See Paine Webber,

87 F.3d at 594.

4 B. Motion to Stay the Proceedings

MNR asks the court to stay the proceedings here for ninety

days after September 28, 2004, pursuant to Federal Rule of Civil

Procedure 8 1 (e). Although MNR asserts that it is entitled to

file a motion to vacate the award within one year, as provided by

RSA 542:8, it states that it intends to file its motion within

ninety days as provided under the FAA, 9 U.S.C. § 12. MNR asks

the court not to consider Leader's motion to confirm the award

and to stay the proceedings until it files its motion to vacate.

Leader objects and asserts that under 9 U.S.C. § 12, MNR would

have only three months after August 24, 2004, to file a motion to

vacate.

RSA 542:8 does not apply in this case. Under the FAA, a

party has ninety days to challenge the arbitrator's award. 9

U.S.C. § 12; Prudential-Bache Securities, Inc. v. Tanner, 72 F.3d

234, 239 (1st Cir. 1995). The ninety-day period begins when the

award is "filed or delivered." 9 U.S.C. § 12. As long as the

arbitral award resolves the parties' claims, it is final when it

is filed or delivered and the time under § 12 begins to run,

although the arbitrators may retain jurisdiction to consider

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