In Raymond James Fin. Servs., Inc. v. Bishop, No. 09-1038, the Fourth Circuit addressed the issue of a decision by the district court vacating an award of compensatory damages rendered by an arbitration panel for three former employees of defendant-company for wrongful termination.
As stated in the decision: "Notwithstanding that the appellant's fundamental claim was one for wrongful termination, we agree with the district court that the award in this case cannot be understood as based on anything other than the arbitrator's finding that defendant committed a breach of fiduciary and legal duties when its in-house lawyer, Bostic, provided legal representation to the appellants in third-party arbitration proceedings."
Then the court found that the arbitration panel committed no mere error of law in rendering an award whose underlying legal basis exceeded the bounds of arbitrable employment-related disputes cognizable under National Association of Securities Dealers Rule 10101.