Summary

Smarter Tools Inc. ("STI") appeals from the February 26, 2021 judgment of the United States District Court for the Southern District of New York (Alison J. Nathan, J.) denying STI's petition to vacate an arbitral award and granting Chongqing SENCI Import & Export Trade Co., Ltd.'s and Chongqing AM Pride Power & Machinery Co. Ltd.'s (collectively, "SENCI") cross-petition to confirm that award. The district court agreed with STI that the arbitrator exceeded his authority by failing to provide a reasoned award as requested by the parties. See Smarter Tools Inc. v. Chongqing SENCI Imp. & Exp. Trade Co., No. 18-cv-2714 (AJN), 2019 WL 1349527, at *4 (S.D.N.Y. Mar. 26, 2019). The district court remanded to allow the arbitrator to issue a reasoned award. Id. at *5. On remand, the arbitrator issued a final amended award, which STI again challenged in district court on the grounds that the award was not reasoned and that it reflected a manifest disregard of the law, and which SENCI again cross-petitioned to confirm. The district court denied STI's petition to vacate the award and granted SENCI's cross-petition to confirm the award. See Smarter Tools Inc. v. Chongqing SENCI Imp. & Exp. Trade Co., No. 18-cv-2714 (AJN), 2021 WL 766258, at *3 (S.D.N.Y. Feb. 26, 2021).

STI's primary argument on appeal is that the district court erred in remanding for the arbitrator to issue a reasoned award, in contravention of the doctrine of functus officio and the Federal Arbitration Act. Absent a finding of ambiguity, or a minor clerical error, STI argues, once the district court determined that the arbitrator exceeded its authority by failing to issue a reasoned award, the only remedy available was vacatur. STI also argues that the arbitrator's amended award was again not reasoned and reflected a manifest disregard of the law. We disagree.

Affirmed.