The Utah Supreme Court held:
(1) When reviewing arbitration awards, the principle that courts must always resolve all doubts in favor of arbitration only applies to the scope of arbitrable issues.
(2) Courts are not required to always favor arbitration awards in every aspect of their review. Instead, courts must assess whether an arbitrator exceeded the authority granted by the parties or any other bases for vacating, modifying, or correcting an award. An arbitrator can exceed their authority by granting an award on an unsubmitted claim.