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In re the Arbitration between Oahuan, Ltd. & Trustees of Violet K. Maertens Trust Estate

Citations: 4 Haw. App. 295; 666 P.2d 603; 1983 Haw. App. LEXIS 119Docket: NO. 8752; SPECIAL PROCEEDINGS NO. 5642

Court: Hawaii Intermediate Court of Appeals; June 22, 1983; Hawaii; State Appellate Court

Narrative Opinion Summary

This case involves an appeal by lessors, Trustees of a trust estate, against the confirmation of an arbitration award that set the lease rent for a lessee at $35,880 annually. The primary legal issue revolves around whether the arbitration award can be vacated or modified under Hawaii Revised Statutes sections 658-9 and 658-10. The Trustees own a property with a cooperative apartment complex, leased under agreements from 1956, which allow for rent adjustments every ten years after an initial fixed term. Following a disagreement over the rent adjustment due in 1981, arbitration was initiated and resulted in a decision favoring the lessee. The Trustees contested the award, claiming arbitration misinterpretation of lease terms. However, the court affirmed the arbitration, emphasizing the limited scope of judicial review and the binding nature of arbitrators' decisions, as supported by public policy and precedent. The appeal cited the *Loyalty Development Co. Ltd. v. Wholesale Motors, Inc.* case, but the court found no merit in reversing the decision, upholding the arbitrators' broad discretion and authority in interpreting lease terms. Consequently, the trial court's confirmation of the arbitration award was affirmed, maintaining the established rent for the lessee.

Legal Issues Addressed

Arbitration Award Confirmation

Application: The court affirmed the arbitration award, highlighting the public policy favoring arbitration to resolve disputes and avoid litigation.

Reasoning: The court affirmed the arbitration award. The court referenced a public policy favoring arbitration to resolve disputes and avoid litigation, supported by prior case law.

Arbitrators' Authority and Decision-Making

Application: Arbitrators possess wide discretion in their decisions and awards, and parties cannot challenge the correctness of their findings on law or facts if made in good faith.

Reasoning: Arbitrators possess broad discretion in their decision-making and awards, with the authority to determine all aspects of submitted issues, including legal interpretations of contract terms.

Binding Nature of Arbitrators' Determinations

Application: The arbitrators' determinations are final and binding on submitted questions, including interpretations of lease terms, equating their role to that of judicial determinations.

Reasoning: The court concluded that the market value determined by the appraisers has the same effect as a court judgment and that the arbitrators’ decisions on submitted questions, including lease term interpretations, are final and binding.

Interpretation of Lease Terms in Arbitration

Application: The interpretation of lease terms related to rent calculations, such as 'exclusive of improvements,' is within the arbitrators' jurisdiction, as demonstrated by the arbitrators' decision being upheld.

Reasoning: The current appeal involves the Trustees' claims that the arbitrators misinterpreted lease language regarding improvements, arguing that such misinterpretation constitutes exceeding their powers.

Limited Judicial Review of Arbitration Awards

Application: Judicial review of arbitration awards is confined to statutory grounds outlined in HRS 658-9 and 658-10, not allowing courts to reassess the merits of the award.

Reasoning: Judicial review of arbitration awards is severely limited, with courts confined to specific statutory grounds for vacation or modification under HRS 658-9 and 658-10. Courts are not to evaluate the merits of the award.