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Haskell Co. v. Sherway Application Co.

Citations: 477 So. 2d 1067; 10 Fla. L. Weekly 2410; 1985 Fla. App. LEXIS 16442Docket: Nos. 84-2747, 84-2784

Court: District Court of Appeal of Florida; October 25, 1985; Florida; State Appellate Court

Narrative Opinion Summary

This case involves an appeal by a contractor (Haskell) and a cross-appeal by a subcontractor (Sherway) concerning arbitration outcomes related to construction disputes. Haskell sought to vacate an arbitration award due to alleged arbitrator bias and contended that attorney’s fees should be decided by the court, not included under 'litigation' in the arbitration scope. Sherway, having prevailed in arbitration, sought attorney’s fees, which the trial court initially denied. The appellate court affirmed the arbitration award, finding no merit in claims of arbitrator bias and concluded that Haskell waived its right to contest attorney’s fees by requesting them in its counterclaim. The court reversed the trial court's denial of attorney’s fees to Sherway, emphasizing that such disputes should have been addressed during arbitration to avoid litigation delays. The decision was to affirm in part, reverse in part, and remand for the award of agreed attorney’s fees to Sherway, underscoring the finality and efficiency of arbitration proceedings. Judges Ryder and Frank concurred with this decision.

Legal Issues Addressed

Arbitration Award and Alleged Arbitrator Bias

Application: The court upheld the arbitration award despite claims of arbitrator bias, indicating that the alleged bias did not invalidate the arbitration process.

Reasoning: Haskell appeals the trial court's refusal to vacate an arbitration award due to alleged bias of one arbitrator.

Attorney’s Fees in Arbitration

Application: The court determined that the issue of attorney’s fees should have been contested during arbitration proceedings, as the arbitration was the proper forum for such disputes.

Reasoning: The court emphasized that this issue should have been raised during arbitration, which was designed to prevent litigation delays.

Contractual Interpretation of 'Litigation'

Application: The interpretation of 'litigation' in the contracts was central to the determination of whether attorney’s fees should be awarded by the court or arbitrators.

Reasoning: Haskell acknowledged the damages claims but contended that attorney's fees should be determined by the court, asserting that the term 'litigation' in their contracts did not include arbitration.

Judicial Review of Arbitration Awards

Application: The court's decision to affirm the arbitration award demonstrates the limited scope of judicial review in arbitration matters.

Reasoning: The order confirming the arbitration award was upheld.

Waiver of Rights by Conduct

Application: Haskell was found to have waived its right to contest Sherway's claim for attorney’s fees by its conduct during arbitration, specifically by requesting such fees in its counterclaim.

Reasoning: The court concluded that Haskell waived its right to challenge Sherway's entitlement to attorney’s fees by requesting fees in its counterclaim and asserting that court determination was necessary.