ARBITRATION - CAVALIER MANUFACTURING, INC. V. GANT

Cavalier Manufacturing, Inc. v. Gant, [Ms. 1080284, Dec. 20, 2013] __ So. 3d __ (Ala. 2013). Manifest disregard of the law is not a ground upon which to challenge an arbitrator's award. The Federal Arbitration Act ("FAA"), at 9 U.S.C. ¤ 10(a), lists four grounds upon which a court may vacate an arbitration award. A party challenging an arbitration award cannot use "manifest disregard of the law" as a shorthand reference to these ¤ 9 grounds, but "must frame its arguments by specific reference to the ¤ 9 grounds." Because the defendant did not do that here, the Court affirms the denial of the motion to vacate the arbitration award. The Court further notes that the ¤ 9 grounds "misconduct, misbehavior, or exceeding of powers by the arbitrator [are not met] simply because an arbitrator might have decided an issue incorrectly." The Court goes on to discuss the limited scope of the ¤ 9 grounds.