J.P. Stevens & Co. v. Rytex Corp. provided the New York Court of Appeals with an excellent opportunity to resolve the vexing problem caused by an arbitrator's duty to disclose information likely to create an impression of bias. Unfortunately, rather than formulate a logical rubric for deciding future cases, the court made inconsistent statements which will only nurture the confusion and uncertainty that has already characterized this issue.
Douglas, Robert L.
"J.P. Stevens & Co. v. Rytex Corp.,"
Hofstra Law Review: Vol. 3
, Article 7.
Available at: http://scholarlycommons.law.hofstra.edu/hlr/vol3/iss1/7