Spicuzza

MEMORANDUM ***

Gail Spicuzza appeals the district court’s decision denying vacatur of an arbitration award in favor of Securities Services Network, Inc. We have jurisdiction over this timely appeal under 28 U.S.C. §§ 1291 and 1294(1), and we now affirm.

We review the district court’s legal decisions confirming an arbitration award and denying vacatur de novo. 1 Judicial review of the arbitrators’ decision, however, “is both limited and highly deferential.” 2 An award will not be set aside unless it manifests a complete disregard of the law. 3 It is insufficient that the arbitrators may have failed to understand the law or failed to apply it correctly. 4 In order to overturn the arbitrators’ decision, Spicuzza must demonstrate that the governing law was well-defined, explicit, and clearly applicable, and that the arbitrators recognized the applicable law and ignored it. 5 In our review we may affirm the judgment of the district court on any ground fairly supported by the record.

Spicuzza contends that the arbitration award must be vacated, as a matter of law, because the arbitrators manifestly disregarded the explicit statutory language of Hawaii Securities Act, HRS §…