No. 25-504

Robert Zeidman v. Lindell Management LLC

Lower Court: Eighth Circuit
Docketed: 2025-10-23
Status: Denied
Type: Paid
Amici (1) Experienced Counsel
Tags: arbitration-act circuit-split federal-arbitration judicial-review manifest-disregard vacatur
Key Terms:
Arbitration Privacy
Latest Conference: 2026-01-09
Question Presented (AI Summary)

Whether the Federal Arbitration Act allows a court to vacate an arbitration decision on the ground that the decision was based on a manifest disregard of the law

Question Presented (OCR Extract)

In Hall Street Associates, LLC v. Mattel, Inc. , this Court held that the statutory grounds expressly enumerated in 9 U.S.C. § 10 are the Federal Arbitration Act’s “exclusive grounds” for vacating an arbitration decision. 552 U.S. 576, 584 (2008). Two years later, in Stolt -Nielsen S.A. v. AnimalFeeds International Corp. , this Court did “not decide whether ‘manifest disregard’ survives our decision in Hall Street Associates . . . as an independent ground for review or as a judicial gloss on the enumerated grounds for vacatur set forth at 9 U.S.C. § 10. ” 559 U.S. 662, 672 n.3 (2010) . Since then, the lower courts have sharply divided on the question this Court left open in Stolt -Nielsen , with six circuits and three state supreme courts holding that manifest disregard remains a valid basis for vacatur and three circuits and two state supreme courts holding that it does not. In the decision below, the Eighth Circuit ordered an arbitration decision vacated based on the “extra statutory standard[]” that the arbitrators manifestly disregarded the law. Pet. App. 12a, 16a . The question presented is: Whether the Federal Arbitration Act allows a court to vacate an arbitration decision on the ground that the decision was based on a manifest disregard of the law .

Docket Entries

2026-01-12
Petition DENIED.
2025-12-10
DISTRIBUTED for Conference of 1/9/2026.
2025-11-24
Amicus brief of Hon. Abraham D. Sofaer submitted.
2025-11-24
Brief amicus curiae of Hon. Abraham D. Sofaer filed.
2025-10-21
Petition for a writ of certiorari filed. (Response due November 24, 2025)

Attorneys

Hon. Abraham D. Sofaer
Elliot FriedmanFreshfields US LLP, Amicus
Elliot FriedmanFreshfields US LLP, Amicus
Robert Zeidman
Peter K. StrisStris and Maher, Petitioner
Peter K. StrisStris and Maher, Petitioner