49 N.Y.2d 950 (1980)
Newly discovered evidence is not a valid ground for vacating an arbitration award under CPLR 7511(b), particularly in compulsory arbitration scenarios like those arising from New York’s no-fault insurance law, where judicial review is limited to instances of irrationality, bad faith, or violation of public policy.
Summary
Central General Hospital sought arbitration to recover payment from Hanover Insurance under New York’s no-fault law. Hanover claimed payment was made but couldn’t produce a canceled check. The arbitrator ruled for the hospital, awarding attorney’s fees. Later, Hanover found the check and sought to vacate the award based on newly discovered evidence. The Supreme Court granted the vacatur, but the Appellate Division reversed, reinstating the award (reduced to only attorney’s fees by consent). The Court of Appeals affirmed, holding that newly discovered evidence is not a ground for vacating an arbitration award under CPLR 7511(b) and finding no basis to disturb the arbitrator’s decision, especially given the limited judicial review applicable to compulsory no-fault arbitrations.
Facts
Central General Hospital, as assignee of Karla Brandstetter, claimed Hanover Insurance failed to pay a bill under New York’s no-fault law (Insurance Law, Article 18).
Hanover asserted payment was remitted but couldn’t produce the canceled check as proof.
The arbitrator granted Hanover an extension to locate the check, but it remained unfound.
The arbitrator ruled in favor of the hospital, awarding the unpaid bill amount plus attorney’s fees under Insurance Law § 675(1).
A month later, Hanover found the canceled check.
Procedural History
Hanover brought a proceeding in Supreme Court to vacate the arbitration award based on newly discovered evidence (the canceled check).
Special Term (Supreme Court) granted Hanover’s application to vacate the award.
The Appellate Division reversed the Supreme Court’s decision and reinstated the arbitration award, reduced to the attorney’s fee amount by consent of the hospital.
The Court of Appeals affirmed the Appellate Division’s order.
Issue(s)
Whether newly discovered evidence constitutes a valid basis for vacating an arbitration award under CPLR 7511(b), specifically in the context of compulsory arbitration under New York’s no-fault insurance law.
Holding
No, because CPLR 7511(b) does not list newly discovered evidence as a ground for vacating an arbitration award, and judicial review of compulsory arbitration under New York’s no-fault law is limited to instances of irrationality, bad faith, or violation of public policy, none of which were present here.
Court’s Reasoning
The Court of Appeals stated that the discovery of new evidence is not among the grounds for vacating an arbitration award under CPLR 7511(b), citing Kwasnik v Willo Packing Co., 61 A.D.2d 791 (1978); Matter of Ganser [New York Tel. Co. of Amer.], 41 A.D.2d 914, aff’d, 34 N.Y.2d 717 (1974); and Matter of Mole [Queens Ins. Co.], 14 A.D.2d 1 (1961).
The court emphasized that because the arbitration was compulsory under the no-fault law (Insurance Law § 675(2)), judicial intervention is limited. The court referenced Matter of Levine v Zurich Amer. Ins. Co., 49 N.Y.2d 907, 908-909 (1980), and other cases to underscore the restricted scope of review.
The Court found no irrationality in the arbitrator’s requirement for proof of payment via a canceled check, nor in the decision favoring the hospital when such proof was not provided. The court found no question as to the good faith of the award or any alleged violation of constitutional rights or strong public policy, referencing Matter of Furstenberg v Aetna Cas. & Sur. Co., 49 N.Y.2d 757, 759 (1980).
The court concluded, “We can perceive no irrationality in an arbitrator’s demand that payment be proved by exhibiting a canceled check or in his decision in favor of the hospital when such proof was not presented.”