Last October, the Supreme Court vacated the Ninth Circuit's opinion in Comedy Club, Inc. v. Improv West Associates, and remanded the case for further consideration in light of Hall Street Associates. In the vacated opinion, the Ninth Circuit had vacated an arbitration award, finding that the arbitrator had acted in manifest disregard of law. On remand, the Appellee filed an initial brief, the Appellant filed a responsive brief, and the Appellee filed a reply brief. The case is now fully briefed. As of this writing, oral argument had not been scheduled. We will continue to monitor this case, which may provide authoritative guidance as to whether the manifest disregard of law doctrine survived the Supreme Court's Hall Street Associates opinion.
This post written by Rollie Goss.