Second Circuit Sets Higher Burden to Prove Evident Partiality of Party-Appointed, Non-Neutral Arbitrators

In Certain Underwriting Members of Lloyds of London v. Florida, Department of Financial Services, the US Court of Appeals for the Second Circuit held that, because a non-neutral party-appointed arbitrator is expected to advocate for the appointing party, there is a higher burden to prove evident partiality on the part of that arbitrator.

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