Robert Zeidman v. Lindell Management LLC

In Hall Street Associates, LLC v. Mattel, Inc., this Court held that the statutory grounds expressly enumerated in 9 U.S.C. § 10 are the Federal Arbitration Act’s “exclusive grounds” for vacating an arbitration decision. 552 U.S. 576, 584 (2008). Two years later, in Stolt-Nielsen S.A. v. AnimalFeeds International Corp., this Court did “not decide whether ‘manifest disregard’ survives our decision in Hall Street Associates . . . as an independent ground for review or as a judicial gloss on the enumerated grounds for vacatur set forth at 9 U.S.C. § 10.” 559 U.S. 662, 672 n.3 (2010). Since then, the lower courts have sharply divided on the question this Court left open in Stolt-Nielsen, with six circuits and three state supreme courts holding that manifest disregard remains a valid basis for vacatur and three circuits and two state supreme courts holding that it does not. In the decision below, the Eighth Circuit ordered an arbitration decision vacated based on the “extrastatutory standard[]” that the arbitrators manifestly disregarded the law. Pet. App. 12a, 16a. The question presented is: Whether the Federal Arbitration Act allows a court to vacate an arbitration decision on the ground that the decision was based on a manifest disregard of the law.