The 9th Circuit has found that the doctrine of "manifest disregard of the law" is still available as a potentioal 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 Circuit has now joined the 2nd Circuit, which dealt with the issue in Stolt-Nielsen SA v. AnimalFeeds International Corp., 548 F.3d 85 (2nd Cir. 2008), in the finding that Hall Street did not abrogate the doctrine. These cases hold that manifest disregard continues to constitute a valid ground for vacatur of an arbitral award, notwithstanding the Supreme Court's ruling in Hall Street.
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