Reported / Citable
Background
Carmon Gaddie filed an American Arbitration Association claim alleging that Experian Information Solutions violated the Fair Credit Reporting Act by reporting inaccurate tradelines and disregarding his identity-theft claims. On March 12, 2026, the arbitrator ruled for Experian.
Gaddie then asked the federal district court to vacate the award under Section 10 of the Federal Arbitration Act. He argued that the arbitrator refused to consider material identity-theft evidence, improperly credited declarations concerning reinsertion notices, failed to evaluate the reasonableness of Experian’s reinvestigation procedures, and manifestly disregarded the FCRA.
The Court’s Holding
The court denied Gaddie’s motion. It found that the arbitrator had considered his identity-theft evidence but deemed it insufficient, made credibility determinations concerning Experian’s evidence, and expressly evaluated the asserted reinvestigation claims. Disagreement with those conclusions did not establish arbitrator misconduct under the FAA’s narrow vacatur standards.
The court also held that manifest disregard of the law is not an independent ground for vacatur under the FAA. Because the award was not vacated, modified, or corrected, the court concluded that Section 9 required confirmation. It confirmed the award—which provided that Gaddie take nothing, that each side bear its own attorneys’ fees, and that arbitration costs remain borne as incurred—and dismissed the case.
Key Takeaways
- A court reviewing an arbitration award does not reconsider the arbitrator’s weighing of evidence or credibility determinations merely because a party disputes the result.
- The record showed that the arbitrator considered Gaddie’s identity-theft evidence and FCRA reinvestigation arguments, defeating his claims of refusal to hear material evidence or other misconduct.
- Manifest disregard of federal law did not supply a separate basis for vacatur, and confirmation was required once no statutory ground for disturbing the award remained.
Why It Matters
The order illustrates the highly deferential review applied to arbitration awards. A losing party cannot obtain vacatur by reframing disagreements over evidentiary sufficiency, witness credibility, or application of substantive law as arbitrator misconduct.
For FCRA litigants, the decision also shows that arbitration does not receive ordinary appellate-style merits review in federal court. A challenge must fit one of the FAA’s limited statutory grounds.