Hall Street Associates, L.L.C. v. Mattel, Inc., 552 U.S. 576 (2008), was a United States Supreme Court case that held that state and federal courts cannot, on a motion to vacate or to modify an arbitration award, expand the limited scope of judicial review specified in 9 U.S.C. §§ 10 and 11, including terms that were agreed upon by the parties.
Background
Toy manufacturer Mattel was sued by its landlord Hall Street Associates in a dispute over a property lease, the property being a former View-Master factory in Beaverton, Oregon where significant pollution was found. After the litigation went to federal court, both parties agreed to resolve the case by arbitration according to the procedures outlined in the Federal Arbitration Act (FAA). Atypically, the parties' arbitration agreement stipulated that the District Court could override the arbitrator's decision if "the arbitrator's conclusions of law are erroneous." That provision of the agreement granted the federal courts a much broader role in supervising the arbitration than is specifically granted in the Act, which explicitly mentions only a narrow set of circumstances under which courts can override an arbitration award, such as corruption, partiality, or misbehavior on the part of the arbitrator.
The arbitrator heard the parties' arguments and handed down a decision in favor of Mattel. Hall sought review from the District Court, which found that the arbitrator's decision contained legally erroneous conclusions. Accordingly, the arbitrator ruled for Hall Street, and the District Court affirmed.
On appeal, the U.S. Court of Appeals for the Ninth Circuit ruled that the original arbitration award, favoring Mattel, must stand.