New York Yankees Partnership v. Miller

Background

New York Yankees Partnership and Legends Hospitality, LLC petitioned under Section 9 of the Federal Arbitration Act for confirmation of an arbitration award against William Miller. The petitioners and Miller entered into agreements in 2017 concerning Yankees season tickets, food benefits, and related services for six seating locations at Yankee Stadium. The agreements had a ten-year term ending December 31, 2027.

The agreements treated failure to pay ticket, license, food-and-beverage, and other required fees as a default. They required unresolved disputes to be submitted to binding arbitration and allowed recovery of unpaid amounts and reasonable attorneys’ fees, professional fees, expenses, and litigation costs connected with a default.

For the 2019 season, Miller did not pay fees totaling $378,108.00. The parties arbitrated the dispute before Jay G. Safer. On May 26, 2020, they entered into a settlement agreement resolving the arbitration in favor of the petitioners, and Safer entered an award on consent. On July 29, 2020, with the parties’ consent, Safer modified the award to remove payments for the 2020 season. The resulting award totaled $392,279.25 and covered 2019-season payments and certain other fees and expenses.

The petitioners filed this federal action on July 31, 2020. Miller did not pay the award, respond to the petition, appear in the action, or oppose the petitioners’ motion for summary judgment.

Legal standard

Under Section 9 of the Federal Arbitration Act, a court generally must confirm an arbitration award unless it is vacated, modified, or corrected under the Act. Confirmation is a limited judicial proceeding that turns the arbitration award into a court judgment. Even when a petition is unopposed, the court must review the petitioner’s submissions and determine whether the undisputed facts establish entitlement to judgment as a matter of law.

The court explained that an arbitration award may be vacated in specific circumstances, including fraud or corruption, partiality by the arbitrator, serious procedural misconduct, or an arbitrator’s exceeding the authority granted by the parties.

Analysis and ruling

The court found that no genuine issue of material fact prevented judgment. The award was entered with the parties’ consent after the arbitrator heard the parties’ submissions and oral argument. The court also found that the award fell within the arbitrator’s authority under the agreements and was consistent with provisions allowing recovery of unpaid amounts and reasonable fees and costs.

The court found no evidence that the award was unlawful, arbitrary, or beyond the arbitrator’s powers. The petition to confirm the arbitration award was granted. The Clerk of Court was directed to enter judgment confirming the award in the amount of $392,279.25, terminate the pending motion, and close the case.