Supreme Court Declines Review of Arbitral Awards Case Under FAA Section 10(a)(4)
Summary
On February 23, 2026, the U.S. Supreme Court declined to review the Eleventh Circuit's decision in Visionary Books + Café, LLC v. Bank OZK, affirming that Section 10(a)(4) of the Federal Arbitration Act requires more than a showing that an arbitrator committed error to vacate an arbitral award. The Court applied the Oxford Health Plans standard, which provides that courts must confirm arbitral awards if the arbitrators' reasoning is sound, even if the arbitrator made factual or legal mistakes. The denial lets stand the Eleventh Circuit's ruling that Bank OZK acted in a commercially reasonable manner when it reversed an ACH transaction, rejecting Visionary's claim for over $7 million in damages.
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The U.S. Supreme Court declined to review the Eleventh Circuit's decision in Visionary Books + Café, LLC v. Bank OZK, letting stand the ruling that the standard for vacatur under Section 10(a)(4) of the FAA requires more than showing an arbitrator committed error or even serious error. The Court applied the Oxford Health Plans standard, under which arbitral awards must be confirmed if the arbitrators' reasoning is sound.\n\nParties seeking to vacate arbitral awards under the FAA in the Eleventh Circuit face a high bar and must demonstrate that the arbitrators exceeded their authority, not merely that they erred. This decision reinforces the limited scope of judicial review of arbitral awards and the deference owed to arbitrators' factual and legal determinations.
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