Raymond James Financial Services v. Fenyk

Robert Fenyk (defendant), a stockbroker, was an independent contractor of Raymond James Financial Services (RJFS) (plaintiff). RJFS was based in Florida. Fenyk managed RJFS’s branch office in Vermont. The contract between Fenyk and RJFS contained a Florida choice-of-law provision and an arbitration clause that required any disputes arising out of the independent contractor relationship to be arbitrated. RJFS terminated the independent contractor relationship after Fenyk was accused of alcoholism. Fenyk filed suit in state court, claiming that he was wrongfully terminated due to Fenyk’s sexual orientation and disability status as a recovering alcoholic, which violated Vermont’s employment-discrimination laws. Fenyk withdrew the suit and submitted the claims to arbitration. RJFS argued that Florida law should apply and that Fenyk’s claims were time-barred under Florida’s statute of limitations. The arbitrators agreed that Florida law applied but awarded Fenyk damages on a Florida claim of disability discrimination that Fenyk never asserted. The arbitration panel decided that Fenyk’s mislabeling the claim as one brought under Vermont law rather than Florida law was not a fatal mistake. RJFS motioned the district court to vacate the arbitration award. The district court granted the motion, concluding that the arbitration panel exceeded its powers by awarding damages on a claim Fenyk never asserted and ignoring Florida’s statute of limitations, which rendered the claim time-barred. Fenyk appealed.