The Yale Law Journal

Hiro N. Aragaki

Forum

The Mess of Manifest Disregard

Hiro N. Aragaki

A circuit split is in the making, and it could signal a shift with significant implications for federal arbitration law. Just eighteen months after the U.S. Supreme Court’s March 25, 2008 decision in the controversial case of Hall Street Associates v. Mattel, Inc., three circuits are already in ri…