Focus (Forum & Focus)
Feb. 24, 2009
Award Hesitation
The 9th Circuit has found that the doctrine of "manifest disregard of the law" is still available as a potential ground for vacatur of an arbitrator's award, writes JAMS neutral June R. Lehrman.
FOCUS COLUMN
By June R. Lehrman The 9th Circuit has found that the doctrine of "manifest disregard of the law" is still available as a potential ground for vacatur of an arbitrator's award. Comedy Club Inc. v. Improv West Associates, 2009 DJDAR 1458. This has been in question since the recent U.S. Supreme Court case Hall Street Associates LLC v. Mattel Inc., 128 S.Ct. 1396 (2008), which cast doubt on the doctrine's future. The 9th Ci...
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