## Facts

- Elaine Williams was a partner at the law firm Katten, Muchin, & Zavis.
- As part of her relationship with the firm, Williams signed an arbitration agreement that incorporated the rules of the American Arbitration Association (AAA).
- A workplace discrimination dispute arose between Williams and the firm.
- Williams attempted to file and litigate her discrimination claims in federal district court, but the firm successfully moved to compel arbitration based on the arbitration agreement.
- In preparing for the arbitration hearing, Williams served discovery requests that included seeking depositions of four identified individuals.
- At a prehearing discovery conference, the arbitrator reviewed Williams’s deposition requests and allowed only one deposition.
- The arbitrator denied three requested depositions and gave reasons for each denial, explaining that the requested testimony would be inappropriate, redundant, or unnecessary in light of the issues and other available proof.
- After the arbitration hearing, the arbitrator issued an award in Williams’s favor, but the award did not include the full front pay or compensatory damages Williams sought.
- Williams returned to federal court and moved to vacate the arbitration award and reinstate her discrimination claims, arguing (among other things) that the arbitrator’s denial of the three depositions denied her a fundamentally fair hearing.

## Issues

1. Whether an arbitrator’s denial of three requested depositions during prehearing discovery, after evaluating the requests and giving case-specific reasons, amounts to misconduct or an improper refusal to hear material evidence warranting vacatur under the Federal Arbitration Act.
2. Whether limiting discovery under AAA rules can constitute a denial of a fundamentally fair hearing when the party seeking vacatur cannot show resulting prejudice.

## Decision

- The court denied Williams’s motion to vacate the arbitration award.
- The court declined to reinstate Williams’s discrimination claims in federal court.
- The court held that the arbitrator acted within the authority granted by the parties’ arbitration agreement and the AAA framework when managing prehearing discovery.
- The court found that Williams did not show that the denial of the three depositions deprived her of a fair opportunity to present her case or caused prejudice sufficient to justify vacatur.

## Legal Principles

- Judicial review of arbitration awards under the Federal Arbitration Act is highly limited; courts generally do not reweigh evidence or second-guess routine procedural rulings made in arbitration.
- Vacatur based on arbitrator misconduct (including refusing to hear evidence) requires more than disagreement with the arbitrator’s case-management choices; the moving party must show that the ruling prevented a fair hearing.
- Arbitrators have broad discretion to control the scope of prehearing discovery, and arbitration may use streamlined discovery procedures that differ from federal civil litigation.
- Limits on depositions, standing alone, do not justify vacatur where the arbitrator considers the request, provides reasons for denying it (such as redundancy or lack of need), and the party still has a meaningful chance to present evidence at the hearing.
- A party seeking to set aside an award based on discovery restrictions must show actual prejudice—i.e., that the restriction likely affected the ability to prove the claim or defense in a way that rendered the hearing unfair.

## Conclusion

Williams v. Katten, Muchin, & Zavis denied a post-award effort to overturn an employment-discrimination arbitration result, holding that the arbitrator’s reasoned decision to allow only one of four requested depositions under AAA procedures did not amount to misconduct or a denial of a fundamentally fair hearing, particularly absent a concrete showing of prejudice, and the award therefore stood without reopening the federal discrimination claims.


Williams v. Katten, Muchin, & Zavis, 1996 WL 717447