Lockhart v. American Reserve Insurance

440 N.E.2d 1219, 2 Ohio App. 3d 99, 2 Ohio B. 112, 1981 Ohio App. LEXIS 9918
CourtOhio Court of Appeals
DecidedJune 4, 1981
Docket42899
StatusPublished
Cited by74 cases

This text of 440 N.E.2d 1219 (Lockhart v. American Reserve Insurance) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lockhart v. American Reserve Insurance, 440 N.E.2d 1219, 2 Ohio App. 3d 99, 2 Ohio B. 112, 1981 Ohio App. LEXIS 9918 (Ohio Ct. App. 1981).

Opinions

Day, J.

This is . an appeal by defendant-appellant, American Reserve Insurance Co. (defendant), from a judgment of the Cuyahoga County Common Pleas Court awarding $12,500 to plaintiff-appellee, Herbert D. Lockhart (plaintiff), under terms of his insurance coverage with defendant.

The judgment is reversed and the case dismissed.

Plaintiff was injured and his motorcycle destroyed on May 15,1977, when he was struck at E. 93rd Street and Gibson Avenue by a car driven by an uninsured motorist. Plaintiff filed a claim with defendant insurance company. After plaintiff heard nothing from the company for some time he filed suit in common pleas court.

Defendant pointed out that the insurance policy contained a mandatory arbitration clause. 1 A panel was chosen pursuant to the clause and met in January 1980. Apparently the arbitrators found the uninsured motorist negligent and made an award. From a letter written by the chairman of the panel to the parties’ attorneys (Exhibit C) it is clear that a unanimous decision was written and signed but not physically delivered to the parties. The parties seem to agree that the amount of that award was $6,000. 2

Subsequently, at the request of plaintiffs attorney who “had learned of the amount to be awarded to his client” (Exhibit C), the panel was reconvened in May 1980. The source of the leak does not appear in the record. However, during oral argument counsel for defendant conceded that he called the chairman of the panel, learned of the award and immediately notified the plaintiffs attorney.

On May 6 the same panel of arbitrators with one dissent, awarded $12,500 to plaintiff and $2,000 to his wife.

The common pleas court retained jurisdiction on plaintiffs original suit while the arbitration process adopted in the insurance policy was pursued. At a pre-trial hearing in common pleas court subsequent to issuance of the second award, the court asked each party to file a motion for summary judgment upon which it would base its findings. The court granted summary judgment for the plaintiff for $12,500 and for defendant and against plaintiff on the $2,000 award to his wife.

From this judgment defendant appeals, assigning one error:

*101 “Assignment of Error No. I:
“The trial court erred when it rendered summary judgment in favor of appellees for Twelve Thousand Five Hundred Dollars ($12,500.00) when pursuant to an arbitration provision in an insurance contract a three person arbitration panel chosen by the parties rendered a unanimous and binding written decision in favor of appellees for Six Thousand Dollars ($6,000.00).”

For reasons adduced below the assignment is well taken.

I

R.C. Chapter 2711 is the Ohio statute governing arbitrations. R.C. 2711.01* 3 provides:

“A provision in any written contract * * * to settle by arbitration a controversy thereafter arising out of such contract * * * shall be valid, irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of any contract.”

Agreements to arbitrate can be enforced in the court of common pleas having jurisdiction of the party failing to perform. 4

And when it appears in “any suit or proceeding” that the issue is arbitrable under an agreement in writing, the court “in which such suit is pending” is required to stay the proceeding upon the application of a party until the arbitration is had. 5 A gap in the procedure for appointing an arbitrator can be filled by common pleas court also on application of a party. 6

Once an arbitration is completed it is apparent that a court which has stayed or ordered enforcement of the agreement to arbitrate has no jurisdiction except to confirm, vacate, modify, or enforce the award and only on the terms provided by statute, i.e., R.C. 2711.09 and R.C. 2711.12 (confirm and enter judgment); R.C. 2711.11 (modify); R.C. 2711.10* and 2711.13* (vacate); or R.C. 2711.14 (enforce the award).

These special statutory sections provide the only procedures for post award attack or support of an arbitration decision. However, an appeal may be taken “from an order confirming,, modifying, correcting, or vacating an award made in an arbitration proceeding or from judgment entered upon an award.” 7 But the review is confined to the order. The original arbitration proceedings are not reviewable. 8

The statute requires that the award be in writing and signed by a majority of the arbitrators and a “true copy of such award” delivered to each of the parties. 9

II

The agreement to submit to arbitration describes the issues and defines the' perimeters of the arbitration tribunal’s powers with respect to them. When the submitted issues are decided, the arbitrators’ powers expire. 10 Thus, a second *102 award on a single, circumscribed submission is a nullity, cf. Bayne v. Morris (1863), 68 U.S. (1 Wall.) 97, 99.

III

In the present case it is established by a letter from the chairman of the arbitration panel to the parties’ attorneys 11 that a first (original) award was reduced to writing and signed. It is clear that no “true copy of such award” was ever physically “delivered to each of the parties in interest” nor included in the record.

Whether the failure to physically deliver can be cured by constructive delivery without violating the statute, whether there was constructive delivery, what consequences follow flawed delivery and the remedy under the circumstances of this case are central to this appeal.

IV

Once a decision was reached in this case, reduced to writing and signed by at least a majority of the panel, the arbitrators’ powers were extinguished unless there was a failure to deliver which preserved their authority and thus allowed a revamping of the original. Under ordinary circumstances it might be defensible to argue that prior to the announcement and the actual delivery a change of arbitrators’ minds could be reflected in a revamped first award because finality had never been achieved.

But the circumstances here are not ordinary. The facts show that. For the change in the original award before literal delivery was stimulated by the defendant’s counsel’s unilateral communication with the chairman of the arbitration panel.

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Cite This Page — Counsel Stack

Bluebook (online)
440 N.E.2d 1219, 2 Ohio App. 3d 99, 2 Ohio B. 112, 1981 Ohio App. LEXIS 9918, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lockhart-v-american-reserve-insurance-ohioctapp-1981.