The U.S. District Court for the Eastern District of Virginia issued a decision holding that an appraisal clause in a commercial property insurance policy was an enforceable arbitration agreement which fell within the scope of the Federal Arbitration Act. Such holding, while not specifically noted by the Court, provides additional support for a party’s right for a due process appraisal where a party is provided the opportunity to present evidence and testimony to the entire appraisal panel.