Introduction In a decision of 23 July 2020 (Docket 18 ONc 3/20s), the Supreme Court dealt with the challenge of an arbitrator on the grounds that he had rolled his eyes during the pleading of a party's representative. The eye rolling, according to the applicants, "downright revealed" the arbitrator's bias. Said arbitrator did not explicitly contest the accusation of having rolled his eyes. Nonetheless, he claimed to be able to objectively give a legal assessment of the facts of the case. In this decision, the Supreme Court: confirmed once again that strict standards for impartially bias apply; confirmed once again that the reasons for challenging state court judges serve as guidelines for challenging arbitrators; and