Appellate Division of the Supreme Court of New York, Second Department Decided: October 29, 2025
Before: Brathwaite Nelson, J.P.; Christopher, Wan, Golia, JJ.
Nature of the Case
This is a proceeding pursuant to CPLR Article 75 to vacate a no-fault insurance arbitration award. Big Apple Pain Management (Big Apple) appeals from a Supreme Court order that vacated a master arbitrator’s award in favor of the medical provider and denied Big Apple’s cross-petition to confirm that award.
Procedural History
- Medical Services: Between February and June 2020, Big Apple provided medical treatment to Carlos Nieto for injuries sustained in a 2019 auto accident.
- Initial Arbitration: Big Apple sought reimbursement of $1,417.73 after American Transit denied the claims. On December 4, 2021, an arbitrator ruled in favor of Big Apple for the full amount.
- Master Arbitration: American Transit appealed. On April 8, 2022, a master arbitrator confirmed the lower arbitrator’s award in its entirety.
- Supreme Court Action: American Transit petitioned to vacate the award. The Supreme Court, Kings County, granted the petition to vacate.
The Appellate Division Ruling
The Appellate Division reversed the lower court’s decision, denying the petition to vacate and granting the cross-petition to confirm the award.
Key Legal Principles Cited:
- Narrow Grounds for Vacatur: Under CPLR 7511, the grounds for vacating a no-fault arbitration award are few and narrowly applied to support the public policy favoring arbitration.
- Arbitrator’s Power: An award is only vacated if it violates strong public policy, is irrational, or clearly exceeds a specifically enumerated limitation on the arbitrator’s power.
- Errors of Law: The court emphasized that a master arbitrator’s determination of the law does not even need to be correct; “mere errors of law are insufficient to set aside the award.”
Conclusion
The Court found that American Transit failed to demonstrate any statutory grounds for vacating the award.
ORDERED: The order is reversed; the petition to vacate is denied; the cross-petition is granted; and the master arbitrator’s award is confirmed.