Schilling v. Allstate Insurance

Chief Justice TROUT,

dissenting.

Because I disagree with the Court’s interpretation of the district court’s authority under the Uniform Arbitration Act, I must respectfully dissent from the Court’s opinion. The district court had no power to modify the award to include prejudgment interest because the arbitrators’ error was not an “evident miscalculation of figures.” The Court correctly states that “[a] district court’s review of an arbitrator’s award is limited to an examination of the award to determine whether any of the grounds for relief provided by the Uniform Arbitration Act (UAA) are present.” Idaho code § 7-*932913 lists as a ground for relief allowing a court to modify or correct the award, “an evident miscalculation of figures.... ” The Court reasons that by failing to include prejudgment interest in the award, the arbitration panel, without question, did not correctly calculate the correct amount of the total award. Thus, the opinion continues, the district court correctly modified the arbitration panel’s award based on “an evident miscalculation of figures.” It is my opinion that the arbitration panel’s failure to award prejudgment is not an evident miscalculation of figures.

This Court has “essentially foreclosed judicial review of the merits of an arbitrator’s award.” Landmark v. Mader Agency, Inc., 126 Idaho 74, 76, 878 P.2d 773, 775 (1994). In Hecla Mining Co. v. Bunker Hill Co., 101 Idaho 557, 617 P.2d 861 (1980) we held that:

The courts are'precluded from considering factual or legal issues which are by voluntary agreement made the subject of arbitration. Judicial intrusion is restricted to the extraordinary situations indicating abuse of arbitral power or exercise of power beyond the jurisdiction of the arbitrator.

101 Idaho at 563, 617 P.2d at 867 (quoting Mobil Oil Corp. v. Local 8-766, Oil, Chemical & Atomic Workers Int’l Union, 600 F.2d 322, 326 (1st. Cir.1979)). Although this Court has, up to this point, only provided an explanation of what an evident miscalculation is not as opposed to what it is, it is my opinion that I.C. § 7-913(a)(l) does not allow courts to modify an award that is incorrect due to an arbitrator’s misinterpretation of law. Rather, the provision anticipates modification of mathematical error. This position is supported by a number of jurisdictions interpreting this provision or similar provisions adopted from the UAA and this Court’s general statements regarding a court’s ability to consider factual and legal issues made the subject of arbitration.

For example, in Palmer v. Duke Power Co., 129 N.CApp. 488, 499 S.E.2d 801 (1998), the arbitrator had failed to include prejudgment interest in the award. The court stated that even if the failure was a mistake of law or fact, such a mistake could not be corrected by the trial court upon a party’s motion for modification or correction because the failure to include prejudgment interest was not due to mathematical error. Id. at 807-08. The North Carolina courts have further explained that the type of error that occurred in this case is not the type of error contemplated by I.C. § 7-913(a)(1). In Carolina Va. Fashion Exhibitors, Inc. v. Gunter, 41 N.C.App. 407, 255 S.E.2d 414 (1979) the court did not allow modification where the party’s argument was an attempt to show a misinterpretation of evidence rather than a miscalculation of figures. Id. at 419. See also School City of East Chicago v. East Chicago Fed’n of Teachers, Local Number 511, 622 N.E.2d 166, 168-69 (Ind.1993) (holding that alteration of an award based on an evident miscalculation must be based upon an improper application of mathematical principles rather than a challenge to the substantive merits of the matter); St. Tammany Manor, Inc. v. Spartan Bldg. Corp., 509 So.2d 424, 427-28 (La.1987) (holding that “the type of ‘evident material miscalculation’ of figures contemplated by the statute would be one akin to an arithmetical error;” where the trial court had examined the legal dispute underlying the award, the trial court’s actions were not statutorily permitted).

In this case, the mistake of the arbitrators was not in improperly calculating the figures used to determine the award or in making some other type of mathematical error. The mistake that the arbitrators made here was in determining that they did not have jurisdiction to award prejudgment interest. While I agree with the Court that the arbitrators were in error in the assessment of their jurisdiction, the error of the arbitrators was one of law and therefore, the district court was without power to either modify or correct the award. Prejudgment interest was necessarily a legal issue that was a subject of the arbitration and courts are precluded from judicial review of such issues. Hecla Mining Co., 101 Idaho at 562, 617 P.2d at 866. As one court stated, “[i]f an arbitrator makes a mistake, either as to law or fact, it is the misfortune of the party____” Cyclone Roofing Co., Inc. v. David M. LaFave Co., Inc., 312 N.C. 224, 321 S.E.2d 872, 880 (1984) (quoting Carolina Va. Fashion Exhib*933itors, 255 S.E.2d at 420) (alterations omitted).1

Because the district court did not have the power to modify the award, I would reverse the decision of the district court. Accordingly, the Court would not need to address whether the arbitration panel had the authority or jurisdiction to award prejudgment interest as an “other expense” pursuant to I.C. § 7-910 or whether the terms of the insurance policy itself precluded the award of prejudgment interest.

Justice WALTERS concurs.

. I note that neither of the two remaining provisions of I.C. § 7-913 would allow the district court to modify or correct the award. The error that occurred here was not one where the “arbitrators ... awarded upon a matter not submitted to them,” nor is the award "imperfect in a matter of form, not affecting the merits of the controversy.” I.C. § 7-913(2), (3). Here, the issue of prejudgment interest had been submitted to the arbitrators. Additionally, altering the award to include prejudgment interest would necessarily require the court to challenge the arbitrator's interpretation of the law and thus any subsequent alteration by the district court would necessarily affect "the merits of the controversy,” a prohibition placed on courts when modifying or correcting awards under I.C. § 7-913(3). See Creative Builders, Inc. v. Avenue Developments, Inc., 148 Ariz. 452, 715 P.2d 308, 313 (1986) (determining whether the trial court had erred in modifying an award to include pre-award interest and holding that the award of pre-award interest went to the merits of the claim itself and thus could not be properly modified under "matter of form.”)