{
  "id": 6136014,
  "name": "200 GARRISON ASSOCIATES LIMITED PARTNERSHIP v. CRAWFORD CONSTRUCTION COMPANY, Inc.",
  "name_abbreviation": "200 Garrison Associates Ltd. Partnership v. Crawford Construction Co.",
  "decision_date": "1996-03-20",
  "docket_number": "CA 94-1325",
  "first_page": "7",
  "last_page": "10",
  "citations": [
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      "cite": "53 Ark. App. 7"
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    {
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      "cite": "918 S.W.2d 195"
    }
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  "court": {
    "name_abbreviation": "Ark. Ct. App.",
    "id": 13370,
    "name": "Arkansas Court of Appeals"
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  "jurisdiction": {
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    "name_long": "Arkansas",
    "name": "Ark."
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      "cite": "294 Ark. 255",
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      "reporter": "Ark.",
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      "reporter": "Ark. App.",
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      "weight": 2,
      "year": 1987,
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    {
      "cite": "Ark. Code Ann. \u00a7 16-108-213",
      "category": "laws:leg_statute",
      "reporter": "Ark. Code Ann.",
      "year": 1987,
      "pin_cites": [
        {
          "page": "(a)(1)"
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  "last_updated": "2023-07-14T22:00:24.662479+00:00",
  "provenance": {
    "date_added": "2019-08-29",
    "source": "Harvard",
    "batch": "2018"
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  "casebody": {
    "judges": [
      "COOPER and Rogers, JJ., agree."
    ],
    "parties": [
      "200 GARRISON ASSOCIATES LIMITED PARTNERSHIP v. CRAWFORD CONSTRUCTION COMPANY, Inc."
    ],
    "opinions": [
      {
        "text": "JOHN Mauzy Pittman, Judge.\nCrawford Construction Company, Inc., appellee, filed a complaint in the Sebastian County Circuit Court against 200 Garrison Associates, appellant, alleging that appellant owed appellee a balance of $154,172.24 on the parties\u2019 breached construction contract. Appellant filed a counterclaim contending that appellee had breached the contract by providing substandard materials and workmanship and erroneous billings. The parties\u2019 contract contained a statutory arbitration clause. The circuit court stayed the proceedings and directed that the parties submit their dispute to arbitration with the American Arbitration Association. Appellant then filed an arbitration claim against appellee, and appellee counterclaimed. On October 25, 1993, the arbitrator denied appellant\u2019s claim, awarded appellee $154,172.24 on its counterclaim and denied appellee\u2019s claim for interest and costs. On January 21, 1994, appellant filed a motion in the circuit court to modify or vacate the arbitrator\u2019s award.\nAfter a hearing, the circuit court held that the arbitrator\u2019s award of $154,172.24 erroneously included $6,908.24 in interest and that appellant failed to demonstrate a miscalculation in the amount of damages awarded. In addition, the court awarded pre- and post-judgment interest on the reduced award of $147,264.00 ($154,172.24 - $6,903.24). The appellant appeals the circuit court\u2019s order arguing that the court erred in affirming the arbitrator\u2019s award of damages and by awarding pre- and post-judgment interest.\nAn arbitrator\u2019s award may be modified or corrected by the court if there is evident miscalculation of figures in the award. Ark. Code Ann. \u00a7 16-108-213(a)(1) (1987). An arbitrator\u2019s decision on all questions of law and fact is conclusive and should be affirmed by the court unless grounds are established to support vacating or modifying the award. McLeroy v. Waller, 21 Ark. App. 292, 731 S.W.2d 789 (1987). Judicial review of an arbitration award is more limited than appellate review of a trial court\u2019s decision; whenever possible, a court must construe an award so as to uphold its validity. Chrobak v. Edward D. Jones & Co., 46 Ark. App. 105, 878 S.W.2d 760 (1994). An award should not be vacated unless it clearly appears that it was made without authority, or was the result of fraud or mistake, or misfeasance or malfeasance. Id. Moreover, the illegality must appear on the face of the award. Id. Even a gross mistake of fact will not vitiate an award unless the mistakes are apparent on the face of the award. Ark. Dep\u2019t of Parks and Tourism v. Resort Managers, Inc., 294 Ark. 255, 743 S.W.2d 389 (1988).\nAppellant first argues that the arbitrator\u2019s award of damages contained miscalculations. Appellant lists in dispute six items under the contract. All are factual issues, and appellant admits that the same evidence presented to the circuit court was presented to the arbitrator. Because there is no mistake evidenced on the face of the arbitrator\u2019s award of damages, the court did not err in finding that appellant had not shown a miscalculation.\nAppellant next argues that the circuit court erred by awarding pre- and post-judgment interest because the arbitrator denied appellee\u2019s request for interest. We agree. Arkansas Code Annotated \u00a7 16-108-213(b) states that unless the award is modified, the court \u201cshall confirm the award as made.\u201d Thus, we reverse the circuit court\u2019s award of interest.\nAppellee cross-appeals the circuit court\u2019s reduction of the award from $154,172.24 to $147,264.00, or $6,908.24, which was allegedly pre-arbitration interest. Appellee argues that the arbitrator granted its claim for $154,172.24. There is no evidence on the face of the arbitrator\u2019s award of $154,172.24 that it included $6,908.24 in interest.\nThere being no evidence that there was a miscalculation on the face of the arbitrator\u2019s award, we remand for the circuit court to enter judgment affirming the arbitrator\u2019s award of $154,172.24.\nAffirmed in part; reversed in part.\nCOOPER and Rogers, JJ., agree.",
        "type": "majority",
        "author": "JOHN Mauzy Pittman, Judge."
      }
    ],
    "attorneys": [
      "Gean, Gean, & Gean, by: Roy Gean, Jr., for appellant.",
      "Harper, Young, Smith & Maurras, PLC, by: Michael K. Redd, for appellee."
    ],
    "corrections": "",
    "head_matter": "200 GARRISON ASSOCIATES LIMITED PARTNERSHIP v. CRAWFORD CONSTRUCTION COMPANY, Inc.\nCA 94-1325\n918 S.W.2d 195\nCourt of Appeals of Arkansas Division I\nOpinion delivered March 20, 1996\nGean, Gean, & Gean, by: Roy Gean, Jr., for appellant.\nHarper, Young, Smith & Maurras, PLC, by: Michael K. Redd, for appellee."
  },
  "file_name": "0007-01",
  "first_page_order": 31,
  "last_page_order": 34
}