Does N.Y. Judiciary Law §487 Apply To Arbitrations?

An attorney violates Section 487 of the N.Y. Judiciary Law (Section 487) when she or he "is guilty of any deceit or collusion or consents to any deceit or collusion with intent to deceive the court or any party..." N.Y. Judiciary Law §487. Such a violation may lead to severe consequences: criminal liability and/or treble damages awarded to the plaintiff. Id. Recently, New York courts have read the statute expansively, concluding that a single act of "intentional deceit" may be enough to impose liability. See, e.g., Dupree v. Voorhees, 102 A.D.3d 912, 913 (2d Dept. 2013) (the "alternative predicate for liability under Judiciary Law §487 based upon an attorney's chronic, extreme pattern of legal delinquency ... should not be followed, as the only liability standard recognized in Judiciary Law §487 is that of an intent to deceive") (internal citations omitted). Perhaps more importantly, in two recent decisions the New York Court of Appeals expanded the statute to cover