gross mistake standard in Texas

2016Dist., 92 S.W.3d 841, 844 (Tex.2002) (per curiam) ("Similarly, assuming without deciding that OISD may rely on the gross mistake standard under the common law to attack the arbitrator’s award.... ”); Ewing v. Act Catastrophe-Tex. L.C., 375 S.W.3d 545, 550 (Tex.App.-Houston [14th Dist.] 2012, pet. denied) ("Presuming, without deciding, that common-law grounds for vacating an arbitration award still may be used to vacate an award under the Texas Act .... ’’); see also Campbell Harrison & Dagley, L.L.P. v. Hill, 782 F.3d 240, 244-45 (5th Cir.2015) (observing that "[t]he Texas Supreme Court has no

2014For example, in addressing gross mistake, a Texas common-law ground for vacating an arbitration award, the Texas Supreme Court “assum[ed] without deciding that [the appellant could] rely on the gross mistake standard - under the common law to attack the arbitrator’s award.” Callahan & Assocs. v. Orangefield Ind. ScK Dist., 92 S.W.3d 841, 844 (Tex.2002); see also Beech Street Corp. v. Baylor Health Care Sys., No. 05-12-01671-CV, 2014 WL 3743864 , at *2 (Tex.App.-Dallas July 29, 2014, no pet. h.) (noting manifest disregard is a federal common-law doctrine while gross mistake is a Texas common-la

2016Dist., 92 S.W.3d 841, 844 (Tex.2002) (per curiam) ("Similarly, assuming without deciding that OISD may rely on the gross mistake standard under the common law to attack the arbitrator’s award.... ”); Ewing v. Act Catastrophe-Tex. L.C., 375 S.W.3d 545, 550 (Tex.App.-Houston [14th Dist.] 2012, pet. denied) ("Presuming, without deciding, that common-law grounds for vacating an arbitration award still may be used to vacate an award under the Texas Act .... ’’); see also Campbell Harrison & Dagley, L.L.P. v. Hill, 782 F.3d 240, 244-45 (5th Cir.2015) (observing that "[t]he Texas Supreme Court has no

2016Dist., 92 S.W.3d 841, 844 (Tex.2002) (per curiam) ("Similarly, assuming without deciding that OISD may rely on the gross mistake standard under the common law to attack the arbitrator’s award.... ”); Ewing v. Act Catastrophe-Tex. L.C., 375 S.W.3d 545, 550 (Tex.App.-Houston [14th Dist.] 2012, pet. denied) ("Presuming, without deciding, that common-law grounds for vacating an arbitration award still may be used to vacate an award under the Texas Act .... ’’); see also Campbell Harrison & Dagley, L.L.P. v. Hill, 782 F.3d 240, 244-45 (5th Cir.2015) (observing that "[t]he Texas Supreme Court has no

2014In his reply brief,-Leonard argues that manifest disregard remains a viable ground for vacating an award, citing Nafta Traders, Inc. v. Quinn, 339 S.W.3d 84, 97 (Tex.2011), which rejected the holding in Hall Street that the parties to an arbitration cannot enter into “an agreement that limits the authority of an arbitrator in deciding a matter and thus allows for judicial review of an arbitration award for reversible error.” The Texas Supreme Court held that the “TAA presents no impediment” to such an agreement.

2002See Teleometrics Int’l, Inc. v. Hall, 922 S.W.2d 189, 193 (Tex.App.-Houston [1st Dist.] 1995, writ denied) (Gross mistake, as a common law ground for setting aside an arbitration award, is a mistake that implies bad faith or failure to exercise honest judgment.).