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Scinto v. Life Insurance Co. of North America
Citation: 20 F. App'x 45Docket: No. 01-7165
Court: Court of Appeals for the Second Circuit; October 3, 2001; Federal Appellate Court
The order affirms the judgment of the United States District Court for the Southern District of New York, which confirmed an arbitration decision that found Paul Scinto not disabled according to his insurance policy terms. Scinto, representing himself on appeal, had previously sued Connecticut General Life Insurance Co. (CG) and the Life Insurance Company of North America (LINA) for breaching disability contracts by denying his claims for benefits post-July 1985. In 1999, the parties agreed to arbitrate the 'validity, extent, and continuity of disability' under the insurance policies, stipulating that a single physician would conduct the arbitration and issue a written decision. The arbitrator found that Scinto was first disabled due to injuries from a gunshot on June 1, 1980, and that he had worked as a microbiologist while pursuing a doctoral degree prior to his disability. He initially received benefits under the 'regular occupation' clause but was determined not to be disabled during critical periods in 1985 when the policies were canceled, as he was engaged in either medical research or illegal activities at that time. Despite evidence of significant health issues post-incarceration, the arbitrator concluded that Scinto was not disabled in July or August 1985, noting that only orthopedic problems were present then, which did not require extensive treatment even 20 years later. The district court confirmed the arbitration decision after finding no manifest errors warranting an overturn. On appeal, Scinto contends that the arbitrator exceeded his authority and misinterpreted facts, arguing that his disabilities stemmed from a 1979 fall and multiple gunshot wounds in 1980, rather than the thigh injury identified by the arbitrator. He also references determinations of disability made by the New York State Higher Education Services Corp., Social Security Administration, and the Internal Revenue Service. Defendants acknowledge that the arbitrator incorrectly assessed the cause of Scinto’s disability but maintain that this error is irrelevant, as the arbitrator correctly evaluated Scinto's disability status in 1985. The review of an arbitrator's decision is conducted with considerable deference, with factual findings reviewed for clear error and legal findings de novo. Arbitration awards are subjected to limited review to maintain the efficiency and cost-effectiveness of arbitration. Under § 10 of the Federal Arbitration Act (FAA), grounds for vacating an arbitration award include fraud, evident partiality, refusal to hear material evidence, exceeding powers, or imperfect execution of powers. Awards can also be modified for evident and material miscalculations or misdescriptions. Notably, an arbitrator's factual errors do not justify reversal. Given that the defendants concede the arbitrator's mistake regarding the cause of Scinto’s injury, the strict review standard does not allow for overturning the decision based on this factual error. Additionally, there is no evidence supporting a reversal on FAA grounds, nor is there evidence of imperfect execution of powers by the arbitrator. The remaining arguments presented by Scinto were found to lack merit.