Hall Street Associates, L.L.C. v. Mattel, Inc.
United States Supreme Court
552 U.S. 576 (2008)
Mattel (plaintiff) leased property from Hall Street Associates (defendant) under a lease requiring Mattel to indemnify Hall Street for environmental law violations; testing later revealed contamination from Mattel's predecessors' manufacturing discharges, and Mattel ultimately entered a cleanup consent order with state regulators and terminated the lease. Hall Street sued Mattel for the cleanup costs under the indemnification clause, and after a bench trial the parties agreed to arbitrate the indemnification issue, with their court-ordered arbitration agreement providing that a court could confirm, vacate, modify, or correct the arbitrator's award through ordinary judicial review — broader review than the FAA itself specifies. After multiple rounds of arbitration and modification attempts, both sides appealed, and the Ninth Circuit ruled for Mattel; the Supreme Court granted certiorari.
Whether, under the Federal Arbitration Act, parties may contractually expand the grounds on which a court may vacate, modify, or correct an arbitration award beyond those specified in the Act.