On June 11, 2024, Justice Cohen of the New York County Commercial Division issued a decision in Royalty Coffee Beans LLC v. H&H Coffee Group Export Corp., 2024 NY Slip Op. 32016(U), holding that an arbitral award was not indefinite simply because it did not explain its reasoning, explaining:
CPLR 7510 provides that the court shall confirm an award upon application of a party made within one year after its delivery to him, unless the award is vacated or modified upon a ground specified in section 7511. Here, the Award was delivered on May 25, 2023, and the Appeal Award was delivered on August 1, 2023, thus the application is timely.
To vacate an award under New York and federal law, the party moving to vacate an arbitration award has the burden of proof, and the showing required to avoid confirmation is very high. It is well settled that a court may vacate an arbitration award only if it violates a strong public policy, is irrational, or clearly exceeds a specifically enumerated limitation on the arbitrator’s power. Moreover, courts are obligated to give deference to the decision of the arbitrator. This is true even if the arbitrator misapplied the substantive law in the area of the contract.
Respondent contends that the Final Award should be vacated for indefiniteness or deficiency under CPLR 7511 because the Arbitration Panel failed to resolve Grand Master Brands, LLC’s (“Grand Master”) counterclaim against Royalty. An award is deficient for purposes of CPLR 7511(b)(1)(iii) and subject to vacatur only if it leaves the parties unable to determine their rights and obligations, if it does not resolve the controversy submitted or if it creates a new controversy.
Respondent’s arguments are unavailing for several reasons. First, this is the same argument upon which H&H based its arbitral appeal, which was rejected by the Appellate Panel. Second, although H&H made a request either to substitute Grand Master in place of H&H or join Grand Master as a co-Respondent, there is no evidence that that the Arbitrators granted that request or that the GCA or the Arbitrators otherwise recognized Grand Master as a party to the Arbitration. Furthermore, Grand Master has not sought to intervene here, and is not a party to this special proceeding. H&H has not cited any authority for the proposition that it would have standing to object to the Petition based on a purportedly unresolved claim asserted by a non-party to this proceeding. Third, the Final Award is clear and unambiguous, adjudging H&H’ s liability in a sum certain, and clarifying the method of calculating interest due to Royalty Coffee on that sum.
The Final Award enables the parties to the arbitration to determine their rights and obligations: H&H must pay Royalty Coffee the amount awarded, plus interest calculated as described by the Final Award. The controversy submitted to the Arbitrators by the two parties to the Arbitration – i.e., whether H&H was liable to refund the credit balance notwithstanding Royalty Coffee’s election not to order more coffee from H&H or from its assignee, Grand Master-was unambiguously resolved in Royalty Coffee’s favor. The fact that the Final Award did not detail the rationale for the Arbitrators’ unanimous decision does not provide a ground for vacating the award.
(Internal quotations and citations omitted).