On 9 April 2009, in ReliaStar Life Insurance Company of New York v. EMC National Life Company, 564 F.3d 81 (2d. Cir. 2009), the United States Court of Appeals for the Second Circuit issued a noteworthy decision regarding sanctions in arbitration proceedings. The Second Circuit reversed the district court in ruling that a contract provision stating that each party will bear the fees of its appointed arbitrator and its own attorneys in an arbitration, does not preclude an arbitrator from awarding such fees as a sanction against a party found to have acted in bad faith during the arbitration. The Second Circuit's ruling does not preclude parties from agreeing to limit the scope of an arbitrator's sanction authority, as long as the parties "explicitly and clearly state that intent as part of their agreement to arbitrate".