Related Professionals
A Stevens & Lee team led by Charles Leasure III successfully argued before the Rhode Island Superior Court to confirm a reinsurance arbitration award in favor of American Fidelity Assurance Company in Neighborhood Health Plan of Rhode Island v. American Fidelity Assurance Company. Notably, the ruling reinforced the strong presumption in favor of arbitration finality in the specialized reinsurance industry.
The dispute involved failures of Neighborhood Health Plan to provide disclosure during the underwriting process for a high-cost medical case. Following arbitration, a three-member panel issued an award in favor of American Fidelity. Neighborhood sought to vacate the award, arguing that the neutral umpire demonstrated “evident partiality” based on prior professional and social interactions with an expert witness.
The court sided with Stevens & Lee’s arguments and rejected that challenge, emphasizing that judicial review of arbitration awards is “exceedingly limited” and begins with a strong presumption of validity.
Applying Rhode Island’s two-part test, the court found no improper interest and no causal connection between the alleged conduct and the outcome. In particular, the court held that the umpire’s prior relationship with the expert — dating back decades — did not constitute disqualifying bias, nor did routine industry overlap, such as serving on arbitration panels or attending professional events. Even the parties’ social interaction at a group concert before the retention of the expert was deemed insufficient, especially where the event was not private, involved others, and did not suggest any financial or personal interest.
The court also emphasized that such professional familiarity is expected, noting that “arbitrators are not automatically disqualified by a business relationship with the parties before them.” Critically, the umpire’s full and complete disclosures further undercut any claim of impropriety.
Equally important, the court found no evidence that the alleged relationship affected the panel’s decision. The petitioner’s arguments were largely speculative and did not establish that the expert’s involvement influenced the award.
Having identified no basis to disturb the decision, the court confirmed the award in full.
This decision highlights that, particularly in specialized industries like reinsurance, professional familiarity among arbitrators and experts is expected and does not, without more, establish bias. Parties challenging arbitration awards must demonstrate both a concrete improper interest and a direct impact on the outcome — an exacting standard that courts will strictly enforce.
