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U.S. Supreme Court holds that the Federal Arbitration Act (FAA) does not authorize contractual expansion of the bases for vacating or modifying arbitration awards.
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Fifth Circuit holds that "manifest disregard of the law" is no longer an independent ground for vacatur of an arbitration award under the FAA.
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Second Circuit recognizes that Hall Street eliminates non-statutory grounds for vacatur under the FAA, but holds that "manifest disregard of the law" is another way of describing the statutory grounds for vacatur found at Section 10(a)(4) of the FAA.
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Ninth Circuit holds that the "manifest disregard" standard for vacatur proceedings is, and always has been, an abbreviation for the statutory grounds for vacatur described in Section 10(a)(4) of the FAA.
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In California, under the California Arbitration Act, parties may by express agreement obtain judicial review of the merits of an arbitration award.
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