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ALABAMA ARBITRATION ACT & MANIFEST DISREGARD OF THE LAW - VOLVO TRUCKS NA, INC. V. DOLPHIN LINE, INC.

In Volvo Trucks NA, Inc. v. Dolphin Line, Inc. [Ms. 1081277] __ So. 3d. __ (Ala. 2010), Dolphin Line alleged claims of breach of contract and misrepresentation against Volvo Trucks NA, Inc. ("Volvo"). The parties eventually agreed to a "Post Dispute Arbitration Agreement" that provided, in part, that the Alabama Arbitration Act would control. At arbitration, Dolphin Line obtained an award of $1,245,348.00. Volvo then filed a motion to vacate the arbitration award, arguing that the award should be set aside as being in manifest disregard of the law. The trial court denied Volvo's motion, and Volvo appealed. On appeal, the Alabama Supreme Court affirmed the denial of Volvo's motion, holding that the manifest-disregard-of-law standard does not remain a viable basis on which to set aside an arbitration award governed solely by the Alabama Arbitration Act.

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