Court of Appeal explains "manifest disregard of the law" standard

The United States Court of Appeals for the District of Columbia Circuit, in a securities case, affirmed the refusal of a District Court to vacate an arbitration award. Appellant conceded that none of the four bases for vacating an award articulated by the Federal Arbitration Act were present, but contended that the award should be vacated nevertheless because the award was “in manifest disregard of the law.” The Court described this standard as requiring that a panel ignore well defined, explicit law that was clearly applicable to the case, and that decisions based upon debatable points of law and disputed issues of fact did not satisfy this standard. Kurke v. Oscar Gruss and Son, Inc., Case No. 05-7018 (D.C. Cir. July 18, 2006).