The 11^th Circuit Court rejected a claim of bias related to interactions between an arbitrator and counsel, citing the interactions were insufficient to warrant impermissible bias on the part of the arbitrator. 

The arbitrator and counsel knew each other as two of three founding members of the International Chamber of Commerce’s Latin American Arbitration Group in 2003 and through an employment relationship, where the arbitrator who as director of the international arbitration program at American University hired counsel as a faculty member for the summer intern program held over sixteen days and after the completion of the subject arbitration but before the final award was issued. 

The court held that the type of interactions between the arbitrator and counsel were nothing beyond the kind of professional interactions that one would expect of successful lawyers active in the specialized area [international arbitration].  Further, the employment relationship was not one in which the arbitrator as the hiring party was in a position to curry favor with counsel.  The fact the employment contacts occurred prior to the issuance of the final award apparently made no difference to the court.

 Federal Deposit Insurance Corp. v. IIG Capital, LLC, 2013 WL 4007573 (11^th Cir. 2013).