Carpenter v. Elway

These four consolidated cases involve application of Mandatory Arbitration Rules (MAR) 6.2, 6.3 and 7.1(a), which set forth procedures for filing an arbitration award, seeking a trial de novo, and entering or vacating judgment on an award. Specifically, we consider the consequences of filing a request for a trial de novo before the arbitrator has filed proof of service of the arbitration award, what constitutes sufficient proof of service, and the minimum requirements for appealing a judgment on an arbitration award.

We hold that a request for a trial de novo is premature if filed before the…