General Re Life Corporation v. Lincoln National Life Insurance Company
United States Court of Appeals for the Second Circuit
909 F.3d 544 (2018)
- Written by Samuel Omwenga, JD
Facts
General Re Life Insurance Corporation (General) (plaintiff) had a contract dispute with Lincoln National Life Insurance Company (Lincoln) that was settled in arbitration. The arbitration panel issued a final decision, which it later clarified in a superseding order. The clarification was over the meaning of ambiguous language in the final order: General thought it meant one thing, Lincoln thought it meant something else, and the panel thought the language meant something altogether different from what both parties thought it meant. After the arbitration panel issued the superseding clarification order, General moved in federal district court to confirm the initial arbitral award on grounds that the superseding clarification order was functus officio, meaning without authority, because the panel had used up its authority when it rendered its initial final award. Lincoln filed a cross-motion for the district court to affirm the arbitration award as modified by the arbitration panel. The district court denied General’s motion and granted Lincoln’s motion to affirm. General appealed.
Rule of Law
Issue
Holding and Reasoning (Pooler, J.)
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