Further, in determining if an arbitrator exceeded her authority in rendering a decision, we will “construe the underlying contract broadly, resolving all doubt in favor of finding that the arbitrator acted within [her] power.” Union River Valley Teachers Ass'n v. Lamoine Sch. Comm. , 2000 ME 57, ¶ 5, 748 A.2d 990. As such, the Court will only vacate an award if the Superior Court itself was compelled to do so. AFSCME, Council 93 v. City of Portland , 675 A.2d 100, 102 (Me.1996) (emphasis added).
[¶ 23] Arbitration appeals are governed by the Maine Uniform Arbitration Act, 14 M.R.S. § 5945(1). Our review of a court's confirmation of an arbitration award is confined to errors of law only, and the award will be upheld unless the court was compelled to vacate it. Randall v. Conley, 2010 ME 68, ¶ 11, 2 A.3d 328 ; Union River Valley Teachers Ass'n v. Lamoine Sch. Comm., 2000 ME 57, ¶ 5, 748 A.2d 990. In reviewing an arbitrator's award directly, the primary issue is whether the award was within the arbitrator's authority.
Appellate review of a court's confirmation of an arbitration award is confined to errors of law only, and the award will be upheld unless the court was compelled to vacate it. See Randall v. Conley, 2010 ME 68, ¶ 11, 2 A.3d 328;Union River Valley Teachers Ass'n v. Lamoine Sch. Comm., 2000 ME 57, ¶ 5, 748 A.2d 990. In reviewing an arbitrator's award directly, the primary issue is whether the award was within the arbitrator's authority.
Appellate review of a court's confirmation of an arbitration award is confined to errors of law only, and the award will be upheld unless the court was compelled to vacate it. See Randall v. Conley, 2010 ME 68, ¶ 11, 2 A.3d 328; Union River Valley Teachers Ass'n v. Lamoine Sch. Comm., 2000 ME 57, ¶ 5, 748 A.2d 990. In reviewing an arbitrator's award directly, the primary issue is whether the award was within the arbitrator's authority.
Interpreting this law, we have held that courts may not vacate an arbitration award merely because the arbitrator erred in interpreting the applicable law. Union River Valley Teachers Ass'n v. Lamoine Sch. Comm., 2000 ME 57, ¶¶ 5, 11, 748 A.2d 990, 991, 993; Cape Elizabeth Sch. Bd. v. Cape Elizabeth Teachers Ass'n, 459 A.2d 166, 174 (Me. 1983); see also Bennett v. Prawer, 2001 ME 172, ¶¶ 8-9, 786 A.2d 605, 608-09; Dep't of Transp. v. Maine State Employees Ass'n, SEIU Local 1989, 606 A.2d 775, 777 (Me. 1992). [¶ 29] This view of arbitration as a process above the substantive law and not bound by it developed in the middle of the last century, when most arbitration agreements, as in Prima Paint, arose from collective bargaining agreements, construction contracts, or other transactions between parties, usually businesses, of relatively equal bargaining power.
Livingstone, 2000 ME 18, at ¶ 11, 746 A.2d at 905 (citing AFSCME, Council 93 v. City of Portland, 675 A.2d 100, 102 (Me. 1996) and Maine Cont. R. Co. v. Bangor Aroostook R. Co., 395 A.2d 1107, 1122 (Me. 1978)). When an arbitrator stays within the scope of its authority, the award will not be vacated even when there is an error of law or fact. See, e.g., Bennett v. Prawer, 2001 ME 172, ¶ 8, 786 A.2d 605, 608; Union River Valley Teachers Assoc. v. Lamoine Sch. Comm., 2000 ME 57, ¶ 5, 748 A.2d 990, 991-92; Board. of Dirs. of Maine S.A.D. 33 v. Teachers' Ass'n, 395 A.2d 461, 463 (Me. 1978); Cape Elizabeth Sch. Bd. v. Cape Elizabeth Teachers' Ass'n, 459 A.2d 166, 174 (Me. 1983). [¶ 9] Moreover, in Livingstone, 2000 ME 18, at ¶ 13, 746 A.2d at 905, we held that the arbitrator did not exceed its authority in selecting one of the apportionment proposals of the parties, even though its selection did not conform to the findings of a hearing officer of the Board.
Even if it were a novel theory, which it is not, "our review of an arbitrator's award is narrow." Union River Valley Teachers Assoc. v. Lamoine Sch. Comm., 2000 ME 57, ¶ 5, 748 A.2d 990, 991. "In determining if an arbitrator exceeded his authority, we construe the underlying contract broadly, resolving all doubt in favor of finding that the arbitrator acted within his power." Id. The client-initiated, compulsory fee arbitration required by Rule 9, results in a court imposed contract that the parties to a fee dispute are deemed to have entered. If the arbitrator commits an error of law, that alone does not mean that the arbitrator exceeded his authority.