Ever since the U.S. Supreme Court’s decision in Hall Street Associates v. Mattel, Inc. in 2008, there’s been a decided split in the federal courts — and therefore a tremendous amount of confusion – as to whether "manifest disregard of the law" still exists as a common law tool for challenging arbitration awards.

On February 16, 2012, the U.S. Court of Appeals for the Fourth Circuit, which handles appeals from the North Carolina’s federal trial courts (as well as from the federal trial courts in MD, VA, WV and SC), finally took its stance in the ongoing circuit-split mess. And at least in this jurisdiction, manifest disregard lives on.

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