Key Takeaway
Court vacates arbitration award when plaintiff denied basic procedural rights including notice, opportunity to be heard, and to present evidence under CPLR Article 75.
Arbitration proceedings must follow established legal procedures to produce valid, enforceable awards. When arbitrators fail to provide parties with fundamental due process rights, courts have the authority to vacate those awards under New York Civil Practice Law and Rules (CPLR) Article 75.
The case of Siegel v Landy demonstrates how critical procedural safeguards protect parties in arbitration. Unlike situations where an arbitrator’s order is not binding where the provider was not named in the underlying arbitration, this case involved a properly constituted arbitration that nonetheless violated basic procedural requirements.
Understanding these protections is essential for anyone involved in arbitration proceedings, whether in no-fault insurance disputes or other legal matters requiring alternative dispute resolution.
Jason Tenenbaum’s Analysis:
Siegel v Landy, 2012 NY Slip Op 03625 (2d Dept. 2012)
There is a right to be able to present evidence at an arbitration…
“However, as the plaintiff correctly contends, the arbitration award, as modified, *3 should have been vacated on the ground that the arbitrator failed to follow the procedures set forth in CPLR article 75 (see CPLR 7511 ). The plaintiff was effectively denied her right to notice, the opportunity to be heard, and the opportunity to present evidence (see CPLR 7506). Accordingly, the Supreme Court should have denied that branch of the defendants’ motion which was to confirm the award, as modified, and granted the plaintiff’s cross motion to vacate the award, as modified”
Key Takeaway
Even when parties agree to arbitration, arbitrators must follow proper legal procedures under CPLR Article 75. Courts will vacate arbitration awards when parties are denied fundamental rights such as adequate notice, the opportunity to be heard, and the chance to present evidence. These procedural safeguards ensure fairness in the arbitration process.
Legal Update (February 2026): Since this post’s publication in 2012, CPLR Article 75 governing arbitration procedures may have been amended through legislative updates or regulatory changes affecting procedural requirements and grounds for vacating arbitration awards. Additionally, case law interpreting due process requirements in arbitration proceedings has continued to evolve, potentially impacting the standards discussed in this analysis. Practitioners should verify current CPLR provisions and recent appellate decisions when evaluating grounds to vacate arbitration awards.
