Ceratosaurus Investors LLC and Canyon Capital Advisors LLC v. Brandon Williams

Background

Ceratosaurus Investors LLC and Canyon Capital Advisors LLC petitioned under the Federal Arbitration Act to confirm and enforce a May 12, 2025 arbitration award against Brandon Williams. The arbitrator awarded $4,295,384.533, consisting of $3,945,182.07 in damages and $350,202.463 in pre-award interest.

The petitioners filed the federal action on May 23, 2025 and submitted evidence concerning the arbitration and the parties’ Claim Sale Agreement. The petitioners later submitted a declaration stating that Williams had been served. They informed the court that Williams said he would not oppose the petition. Williams did not enter an appearance or contest the petition.

Confirmation of the Award

For an unopposed petition to confirm an arbitration award, courts in the Second Circuit treat the request like a motion for summary judgment based on the petitioner’s submissions. The court must still examine those submissions to determine whether the petitioner has shown that no material factual dispute exists and that it is entitled to judgment as a matter of law.

The court found that the arbitrator acted within the scope of his authority and that the arbitration award contained a sufficient factual and legal basis—described as a “colorable justification”—for the arbitrator’s conclusions. The court therefore confirmed the award for $4,295,384.533.

Interest

The petitioners’ request for interest was granted in part. The court awarded pre-judgment interest at nine percent per year under New York law, running from May 12, 2025, the date of the arbitration award, through the date judgment was entered.

The court also awarded post-judgment interest, but it modified the requested rate. Under 28 U.S.C. § 1961, post-judgment interest in a civil case generally accrues at the federal statutory rate unless the contract clearly provides otherwise. The court found that the parties’ contract did not clearly displace that federal rate. Post-judgment interest therefore accrues at the rate set by Section 1961 from the date judgment was entered until the judgment is paid.

Attorneys’ Fees and Costs

The court denied the petitioners’ request for attorneys’ fees and costs associated with the federal proceeding. The petitioners did not provide an assessment of the fees and costs or supporting time records, bills, or receipts. Without that information, the court could not determine the amount or reasonableness of the requested expenses.

Disposition

Judge Victor Marrero ordered that the petition be granted in part and denied in part. The court entered judgment against Williams for $4,295,384.533, plus the specified pre-judgment and post-judgment interest. It denied the petitioners’ request for fees and costs and directed the Clerk of Court to close the case.