Arbitrators are not permitted to award attorneys' fees, with three limited exceptions: (1) where a statute provides for the award; (2) where the award is authorized by an express provision in the agreement; (3) where it is unmistakably clear that the parties intended the award.
Steyn v. CRTV, LLC, NY Slip Op 05341 (1st Dep't July 2, 2019)
Here is the decision.
