Legion Insurance Co. v. Vcw, Inc. Preferred Administrative Services, Inc.

BEAM, Circuit Judge.

The doctrine of functus officio prevents arbitrators from revisiting a final award after the final award has been issued. 2 In this appeal by VCW, Inc., and Preferred Administrative Services, Inc. (PAS), we hold that this doctrine prevented an arbitration panel from rescinding a final arbitration award after a federal district court decided to vacate in part and confirm in part that award. We also hold that the district court erred when it used section 10 of the Federal Arbitration Act (FAA) to both vacate and confirm the award.

I. BACKGROUND

VCW markets insurance policies…