Case Explained: Compeer Financial, ACA; Compeer Financial, PCA; Compeer Financial, FLCA v. Corporate America Lending, Inc

Court: United States Court of Appeals for the Eighth Circuit

Filed: 2026-07-06

The Eighth Circuit affirmed the district court’s judgment confirming a partial final arbitration award and appointing a receiver to enforce that award in a contract dispute involving Farm Credit Act lending associations. The court held that the arbitration panel’s Phase I Award was final and confirmable because it unconditionally determined liability and damages regarding the Payoff Proceeds, leaving no significant issues for the arbitrator to resolve on those specific claims despite retaining jurisdiction over independent counterclaims in Phase II. Furthermore, the court ruled that the award did not violate public policy under the Federal Arbitration Act (FAA) or Hall Street Associates v. Mattel, Inc., because even if the underlying Master Participation Agreement were unenforceable due to statutory violations, the arbitrator independently awarded relief based on alternative claims for unjust enrichment and breach of the implied covenant of good faith and fair dealing. Regarding the appointment of a receiver, the court found no error, determining that the district court acted within its discretion under federal equitable principles and the six-factor test from *Aviation Supply Corp. v. R.S.B.I. Aerospace, Inc.* because CAL’s CEO engaged in extreme noncompliance, concealment, and obstructionist tactics that rendered legal remedies inadequate to protect Compeer’s claim to the funds. As a practical consequence, the district court’s order confirming the award and the appointment of a receiver to identify and recover CAL’s assets to satisfy the arbitration judgment remain in full force.

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