Quinn, Racusin & Gazzola Chartered v. Pavich Law Group, P.C.

Summary

The D.C. Court of Appeals affirmed confirmation of a JAMS arbitrator's final award allocating a 46% contingency fee among four law firms that represented Wye Oak Technology in its litigation against Iraq, an allocation that gave appellant QRG zero percent. The court held QRG failed to establish that the fee agreement's arbitration clause was procured by fraudulent inducement — it identified no false representation relating to the clause — or duress, because WTP's threat to withhold its signature and demand a larger share was a non-actionable economic threat. Reviewing arbitrability de novo, the court held the clause covering disputes 'arising out of or relating to' the agreement encompassed both the fee-allocation dispute and PLG's and WTP's tortious interference and breach-of-fiduciary-duty claims, and that the D.C. Circuit's later vacatur of the underlying judgment did not void the agreement because the judgment had been monetized.