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In Martinique Properties, LLC v. Certain Underwriters at Lloyd\'s of  London, Subscribing to Policy Number W1551E160301; Beazley Lloyd\'s  Syndicate 2623; Beazley Lloyd\'s Syndicate 623, No. 21-3561, United  States Court of Appeals, Eighth Circuit (March 1, 2023) the Eighth  Circuit interpreted the Federal Arbitration Act as applied to an  insurance appraisal. 

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 FACTS  Martinique Properties, LLC sued the Certain Underwriters at Lloyd\'s,  London (Underwriters) seeking to vacate an arbitration award. The  district court dismissed the complaint for failure to state a claim for  vacatur. Martinique Properties appealed.  Martinique Properties owned apartments in Omaha, Nebraska, for which it  had property insurance coverage through Underwriters. In May 2016, while  the policy was in effect, the apartments sustained hail and wind  damage. Martinique Properties submitted an insurance claim for  reimbursement of its repair costs and the Underwriters and Martinique  disputed the amount owed for the repairs.  

The insurance policy included an appraisal provision, which governed the  process for resolving disagreements as to the amount of loss or the  value of the property. Under the provision, a panel of appraisers was to  evaluate the property damage and determine the amount of loss. If the  panel came to a decision, its agreed-upon appraisal award would be  binding on the parties.  Martinique Properties invoked the appraisal provision. A panel of  appraisers agreed on a binding appraisal award in June 2020. The suit  against Underwriters sought a declaration that the appraisal process and  award were invalid. According to Martinique Properties, the award  incorporated incorrect figures and measurements.  The district court granted Underwriters\' motion to dismiss, finding that  none of Martinique Properties\' allegations presented appropriate  grounds for vacatur.  ANALYSIS  The Arbitration Act is a congressional declaration of a liberal federal  policy favoring arbitration agreements. Under the Act a court may only  vacate an arbitration award in four limited circumstances, and in the  absence of one of these grounds, the award must be confirmed.