Court upholds damage calculation by arbitrator in discharge case

Leon Rubenfaer sued PHC of Michigan, arguing a breach of the parties' employment agreement. They had agreed upon binding arbitration, and the arbitrator ultimately awarded Rubenfaer $408,205.00, in part based upon the payments made to Rubenfaer under a contract with a third-party. PHC argued that the arbitrator exceeded her powers by using the third-party contract to calculate Rubenfaer's damages. The Court rejected this argument, noting that the calculation of Rubenfaer's damages was a question of fact, and the related contract was within the arbitrator's province to consider. Defendant was actually complaining about the arbitrator's factual determination regarding what damages were caused by the Defendant's breach, which was, again, a factual issue within the arbitrator's jurisdiction.