In affirming a $15.7 million arbitration award in a real estate dispute, the Pennsylvania Superior Court ruled that courts may infer consent to the majority decision of an arbitration panel when the parties agree to have two partisan arbitrators select a third, neutral arbitrator.

The ruling, outlined in a 33-page unpublished memorandum opinion by Judge Paula Francisco Ott, clarified an exception to the long-standing general rule that common-law arbitration awards must be unanimous.

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