A federal judge has the power to order an arbitrator to clarify his award when later factual developments render the arbitrator’s decision ambiguous so that the judge can decide how to rule on an enforcement action, the 3rd U.S. Circuit Court of Appeals has ruled.

In her 10-page opinion in Official & Professional Employees International Union, Local No. 471 v. Brownsville General Hospital, U.S. Circuit Judge Dolores K. Sloviter found that the arbitrator himself should revisit an award when ambiguities develop in order to preserve the limited role of the courts.

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