Lindland v. United States Wrestling Association
United States Court of Appeals for the Third Circuit
227 F.3d 1000 (2000)
Matt Lindland (plaintiff) and Keith Sieracki both believed they were entitled to be the U.S. Olympic wrestling entrant in a given weight class; Sieracki won their first qualifying match, but Lindland protested and, after USA Wrestling (defendant) rejected the protest, sought arbitration under the Stevens Act. Arbitrator Burns ordered a rematch, which Lindland won, and a federal court upheld Burns's decision, confirming Lindland's entitlement to be USA Wrestling's Olympic nominee. Sieracki then initiated a separate arbitration before Arbitrator Campbell, who directed USA Wrestling to nominate Sieracki based on his win in the first match; USA Wrestling ultimately chose Sieracki citing Campbell's ruling, prompting Lindland to obtain a writ of mandamus requiring compliance with Burns's decision, after which USA Wrestling submitted Lindland's name, but the U.S. Olympic Committee refused to accept him. Lindland returned to federal court seeking to affirm Burns's ruling and compel the USOC to send him; Sieracki argued Lindland was bound by the Campbell decision because he had participated in that hearing, and the trial court agreed with Lindland.
Whether an arbitrator is authorized to rule on the propriety of another arbitrator's decision.