Ad Hoc Research Associates, LLC v. Evan Gertis
Ad Hoc Research Associates, LLC v. Evan Gertis
Opinion
USCA4 Appeal: 25-1074 Doc: 12 Filed: 04/15/2025 Pg: 1 of 3
UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT
No. 25-1074
AD HOC RESEARCH ASSOCIATES, LLC, Plaintiff - Appellee, v. EVAN GERTIS, Defendant - Appellant.
Appeal from the United States District Court for the District of Maryland, at Baltimore.
Brendan A. Hurson, District Judge. (1:24-cv-03069-BAH)
Submitted: April 10, 2025 Decided: April 15, 2025
Before WILKINSON and RUSHING, Circuit Judges, and FLOYD, Senior Circuit Judge.
Affirmed by unpublished per curiam opinion.
Evan Gertis, Appellant Pro Se. Vijay Mani, Aron Lucas Zavaro, THATCHER ZAVARO & MANI, Greenbelt, Maryland, for Appellee.
Unpublished opinions are not binding precedent in this circuit.
USCA4 Appeal: 25-1074 Doc: 12 Filed: 04/15/2025 Pg: 2 of 3
PER CURIAM: Evan Gertis appeals the district court's order granting Ad Hoc Research Associates’s petition for confirmation of its arbitration award and denying Gertis’s motion to dismiss the petition. On appeal, Gertis contends that the award should be vacated because the arbitrator denied him the opportunity to present his case fully. Gertis also claims that he did not violate his employment contract and that Ad Hoc Research Associates had unclean hands and violated their duty of good faith and fair dealing. We affirm.
We review de novo a district court's denial of a motion to vacate an arbitration award. Brown & Pipkins, LLC v. Serv. Emps. Int’l Union, 846 F.3d 716, 723 (4th Cir. 2017). Generally, “judicial review of an arbitration award in federal court is severely circumscribed and among the narrowest known at law.” Jones v. Dancel, 792 F.3d 395, 401 (4th Cir. 2015) (internal quotation marks omitted). “[A] federal court may vacate an arbitration award only upon a showing of one of the grounds specified in the Federal Arbitration Act, see 9 U.S.C. § 10(a).” Patten v. Signator Ins. Agency, Inc., 441 F.3d 230, 234 (4th Cir. 2006). In reviewing an arbitration award, “our province is not to determine the merits of the dispute between the parties but rather to determine only whether the arbitrator did his job—not whether he did it well, correctly, or reasonably, but simply whether he did it.” Interactive Brokers LLC v. Saroop, 969 F.3d 438, 445 (4th Cir. 2020) (internal quotation marks omitted).
Having reviewed the record and the parties’ submissions on appeal, we conclude that Gertis has not met the heavy burden for vacatur of the arbitration award. Indeed, Gertis has not shown that the award was procured by corruption, fraud, or undue means or that USCA4 Appeal: 25-1074 Doc: 12 Filed: 04/15/2025 Pg: 3 of 3
the arbitrator engaged in misbehavior within the meaning of 9 U.S.C. § 10(a)(1), (3), or that the arbitrator manifestly disregarded the law. See Saroop, 969 F.3d at 442 (explaining manifest disregard standard); Wachovia Sec., LLC v. Brand, 671 F.3d 472, 479-80 (4th Cir. 2012) (providing standard for challenge to arbitration award under § 10(a)(3)).
Accordingly, we affirm the district court’s order denying Gertis’s motion to vacate the arbitration award and granting Ad Hoc Research Associates’ petition to confirm the award. We dispense with oral argument because the facts and legal contentions are adequately presented in the materials before this court and argument would not aid the decisional process.
AFFIRMED
Case-law data current through December 31, 2025. Source: CourtListener bulk data.