The United States Court of Appeals for the Ninth Circuit held in a non-reinsurance case that a District Court correctly denied a motion to vacate an arbitration award on the basis that the arbitration panel “manifestly disregarded the law” by applying Washington law, rather than Arizona law, because the decision was not “completely irrational” and did not constitute a manifest disregard of the law. Parsons v. Polen, 2006 WL 1082820, case no. 04-35654 (9th Cir. Apr. 25, 2006) (opinion not available on Court's web site).
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