Background
Eitan Rubin, in his individual capacity, and Reuven Gidanian challenged an arbitration award involving defendant Barnett Brodie. Brodie applied in Connecticut Superior Court to confirm the award.
The plaintiffs did not move to vacate, modify, or correct the award within thirty days after receiving notice of it. The trial court, Ozalis, J., granted Brodie’s application to confirm the award, and the plaintiffs appealed.
The Court’s Holding
The Connecticut Appellate Court affirmed. Under General Statutes § 52-420 (b), a party may not move to vacate, modify, or correct an arbitration award more than thirty days after notice of the award.
That deadline implicates subject-matter jurisdiction. Because the plaintiffs did not timely make such a motion, the trial court lacked jurisdiction to vacate the award, including through opposition to the application to confirm it.
Key Takeaways
- The thirty-day deadline in § 52-420 (b) is jurisdictional.
- An untimely challenge cannot defeat a timely application to confirm an arbitration award.
- The appellate court affirmed confirmation of the award.
Why It Matters
The decision reinforces Connecticut’s strict deadline for judicial challenges to arbitration awards. Parties seeking to vacate, modify, or correct an award must act within thirty days of notice or lose the court’s power to consider the challenge.