Czarnikow-Rionda Co, Inc v. Buenamara Compania NA

In Czarnikow-Rionda Co, Inc v. Buenamara Compania NA, (SDNY Sept 17, 1986), the court refused to set aside an arbitration award signed by two arbitrators where the final award "recited that the unanimous...decisions were reached in joint deliberations between all three members' of the panel before [the third arbitrator] died." The court rejected as speculative the argument that the arbitration should start anew before a three-person panel because the deceased arbitrator might have changed his mind and convinced the balance of the panel before the final award was issued.