The court of appeals affirmed a judgment of the district court. The court held that the district court properly refused to vacate a final arbitration award without a merits review under the exclusive and limited judicial review authorized by §10 of the Federal Arbitration Act.

Dimitrios Biller was employed as in-house counsel for Toyota Motor Sales (TMS) from 2003 to 2007, with responsibilities on product liability matters. In 2007, Biller presented TMS with a claim asserting, among other things, constructive wrongful discharge related to alleged unethical discovery practices by TMS. TMS and Biller settled the claims pursuant to a severance agreement in which Biller agreed to give a broad release of his claims, protect and not disclose Toyota’s confidential information, return Toyota’s confidential information in his possession, and not copy that confidential information. The parties agreed to arbitrate any claims relating to the agreement.