Yaffe
Yaffe v. Smith Barney Division of Citigroup Global Markets, Inc.
Opinion
Lead Opinion
MEMORANDUM **
Steven Yaffe appeals pro se the district court’s refusal to vacate an arbitration award. We conclude the arbitrator’s decision was not made in “manifest disregard for the law” and, accordingly, we affirm.
DISCUSSION
Yaffe sought arbitration after he was discharged from his job at the Smith Barney Division of the Citigroup Global Markets, Inc. (“Smith Barney”) for allegedly engaging in unauthorized trading, failing to follow instructions, and misrepresenting facts to his supervisor. The arbitrator ruled against Yaffe, concluding “the evidence was sufficient to support a reasonable conclusion that Mr. Yaffe did commit the offending acts.” Yaffe moved to vacate the decision, contending the arbitrator failed to address all of his arguments, there was not “good cause” for his termination, Smith Barney failed to investigate and provide him an adequate opportunity to respond to the allegations, and the arbitrator erred by not imposing penalties for Smith Barney’s delays in paying Yaffe his earned commissions and returning his investment funds.
We conclude these arguments are beyond the “extremely limited” scope of review of an arbitration award. See G.C. and K.B.…