Fairness of arbitration awards

1. Whether judicial estoppel may be used to convert a pre-arbitration assertion that a category of claims is arbitrable into a permanent submission of a fraud claim that was never pleaded for decision in the arbitration itself, particularly in light of this Court’s intervening decision in *Keathley v. Buddy Ayers Construction, Inc.* and the limits on arbitral authority imposed by 9 U.S.C. § 10(a)(4). 2. Whether an arbitration is fundamentally fair under 9 U.S.C. § 10(a)(3) where fraud was expressly disavowed during the arbitration, was introduced only in a supplemental post-hearing submission, and the arbitrator closed the proceeding the next day, leaving no meaningful opportunity to defend—yet the reviewing court treated the absence of a pre-award request to reopen as waiver. 3. Whether the extraordinary deference afforded arbitral awards permits confirmation where the award materially omits dispositive contract language, substitutes a contractual standard the parties did not adopt, disregards express force-majeure provisions, and uses those altered contractual premises to impose personal fraud liability.