Ohio law gives extraordinary deference to arbitration. Once parties agree to arbitrate, they agree to accept the arbitrator’s interpretation of both the facts and the contract. Courts are not “super-arbitrators,” and the circumstances in which a judge can undo an award are deliberately narrow.
Why the Bar Is So High
Arbitration is designed to bring disputes to a final and binding conclusion without the time, cost, and unpredictability of litigation. That finality would mean little if every disappointed party could ask a court to re-decide the merits. For that reason, the Ohio General Assembly has sharply limited judicial review through R.C. 2711.10 and 2711.11.
As the Sixth District Court of Appeals recently emphasized, “When agreeing to arbitration, the parties agree to accept the arbitrator’s award even if it results in a legally or factually inaccurate decision.” Univ. of Toledo v. Am. Ass’n of Univ. Professors, 2025-Ohio-3008, ¶ 48.
In other words, even a “wrong” decision is binding, unless it falls within one of the statutory exceptions.
The Four Grounds for Vacating an Award
The only basis for disturbing an arbitrator’s award are found in R.C. 2711.10 and 2711.11. Under R.C. 2711.10, a trial court can vacate an arbitration award in four circumstances:
- The award was procured by corruption, fraud, or undue means.
This covers misconduct that infects the integrity of the process itself. Examples: bribery, falsified evidence, or intentionally misleading the arbitrator. Mere poor judgment or one-sided presentation does not qualify.
- There was evident partiality or corruption on the part of the arbitrators, or any of them.
Courts may vacate if the arbitrator had a clear, undisclosed conflict of interest or financial stake in the outcome. “Evident” means obvious and provable, not simply that the arbitrator ruled against one side.
- The arbitrators were guilty of misconduct in refusing to postpone the hearing, upon sufficient cause shown, or in refusing to hear evidence pertinent and material to the controversy; or of any other misbehavior by which the rights of any party have been prejudiced.
Applies when an arbitrator unreasonably refuses to postpone a hearing, excludes essential testimony, or otherwise prejudices a party’s ability to be heard. Routine evidentiary rulings or limits on cumulative witnesses rarely meet this standard.
- The arbitrators exceeded their powers, or so imperfectly executed them that a mutual, final, and definite award upon the subject matter submitted was not made.
By far the most frequently litigated category. An arbitrator exceeds authority only when the award does not “draw its essence” from the agreement that authorized the arbitration. If there is a rational connection between the contract and the award, even if debatable, the court must confirm it.
The Sixth District put it plainly: “As long as the arbitrator is even arguably construing or applying the contract and acting within the scope of his authority, a court should not overturn the decision.” Id. at ¶ 55, citing Painesville City Local Schools Bd. of Edn. v. Ohio Assn. of Pub. School Emps., 2006-Ohio-3645, ¶ 37 (11th Dist.), and United Paperworkers Internatl. Union, AFL-CIO v. Misco, Inc., 484 U.S. 29, 38 (1987).
That “arguably construing” test is what makes arbitration so durable in court.
Practical Guidance for Parties in Arbitration
Employers and Plan Sponsors
- Define arbitral authority clearly in contracts and policies. Ambiguity expands the arbitrator’s discretion.
- Prepare the record, you will almost never get a second chance in court.
- Reserve challenges for true procedural or jurisdictional errors, not unfavorable reasoning.
Unions and Participants
- Emphasize finality in negotiations: arbitration is only effective if it is respected as binding.
- Cite R.C. 2711 early when opposing improper motions to vacate.
- Preserve transcripts and exhibits to show the arbitrator acted within contractual bounds.
Both Sides
Understand that judicial review exists to police process, not judgment. If the arbitrator acted within the four corners of the contract and followed basic fairness, the award is almost certain to stand.
The Bottom Line
Vacating an arbitration award in Ohio is not a matter of persuading a court that the arbitrator got it wrong. It’s about proving that the arbitrator never had the power to decide it that way in the first place. Unless a challenger can show corruption, bias, procedural misconduct, or a clear departure from the contract, R.C. 2711.09 requires confirmation of the award.
Or, as the Sixth District summarized: “There is a rational nexus between the arbitrator’s award and the agreement, and the award is not arbitrary, capricious, or unlawful—this is where our inquiry must end.” Id. at ¶ 62, citing, Fowler, 2018-Ohio-4052, at ¶ 22 (6th Dist.); Carothers, 2023-Ohio-1907, at ¶ 22 (6th Dist.)