In re the Arbitration between State of New York Office of Mental Health & New York State Correctional Officers & Police Benevolent Ass'n
Judge Mugglin dissents from the majority's decision, which concluded that the arbitrator committed misconduct by excluding pertinent evidence, specifically respondent Taras Neznanyj’s convictions, leading to an irrational factual conclusion. The dissenting judge argues that prejudicial arbitral misconduct was not a basis urged by the petitioner for vacating the award, and an arbitrator only exceeds their power if the award violates public policy, is irrational, or exceeds a specific limitation. The judge contends that the arbitrator acted within their broad powers by choosing not to consider the criminal convictions, as they were not the basis for the original charges, and instead conducted a de novo review, hearing testimony from multiple witnesses. Furthermore, the dissent asserts that arbitrators are not legally required to give collateral estoppel effect to criminal convictions, thus the failure to admit certificates of conviction, when underlying evidence was heard, does not constitute prejudicial misconduct or render the award irrational.