## Facts

- The case arose from intra-family disputes over an estate, trusts, and family corporations, including a corporation holding real property known as Tilden Ranch.
- Leonard K. Hoskins and his brother, Colonel Clifton Hoskins (individually and as independent executor of Hazel Hoskins’s estate), became adverse parties along with Hoskins, Inc.
- In 2002, Leonard, Clifton, and Hazel entered a settlement agreement requiring mediation and, if unsuccessful, binding arbitration for disputes over the agreement’s performance and interpretation.
- A bankruptcy court approved the settlement and issued a permanent injunction limiting suits between the parties concerning the bankruptcy litigation’s subject matter without court permission.
- In 2011, the parties executed a separate arbitration agreement selecting arbitration under the Texas General Arbitration Act (TAA).
- Leonard initiated arbitration asserting claims including fraudulent conveyance and fiduciary-duty breaches related to Tilden Ranch transactions.
- The arbitrator rejected most of Leonard’s claims, relying on limitations defenses and lack of standing.

## Issues

1. Whether a court may vacate an arbitration award under the TAA based on extra-statutory, common-law grounds such as “manifest disregard of the law.”
2. Whether the TAA’s vacatur provisions (including Tex. Civ. Prac. & Rem. Code § 171.088) are exclusive.
3. Whether Leonard was denied a hearing required by the TAA in the trial court proceeding to confirm or vacate the award.

## Decision

- The Supreme Court of Texas affirmed confirmation of the arbitration award.
- The Court held that the TAA’s statutory grounds for vacatur are exclusive and cannot be supplemented by common-law doctrines, including “manifest disregard of the law.”
- The Court rejected Leonard’s contention that he was denied a statutory hearing, concluding the trial court acted within the TAA framework and no statutory basis for vacatur was shown.

## Legal Principles

- Under the TAA, a court must confirm an arbitration award unless a statutory ground is established for vacatur, modification, or correction.
- The vacatur grounds enumerated in Tex. Civ. Prac. & Rem. Code § 171.088 leave no residual authority for courts to add extra-statutory vacatur theories.
- “Manifest disregard of the law” is not an independent ground to vacate an award under the TAA.
- Judicial review of TAA arbitration awards is narrowly limited to the statute’s specified defects (e.g., corruption, evident partiality, misconduct prejudicing rights, exceeding powers, or lack of an agreement to arbitrate).
- A party’s disagreement with an arbitrator’s legal determinations does not, by itself, establish a statutory defect or a denial of any hearing required by the TAA.

## Conclusion

The Texas Supreme Court held that courts may vacate TAA-governed arbitration awards only on the grounds the legislature listed, rejecting “manifest disregard of the law” as a nonstatutory basis for vacatur and affirming confirmation of the award.


Hoskins v. Hoskins, 497 S.W.3d 490 (Tex. 2016)