Stolt-Nielsen v. Animalfeed Int'l Corp. (U.S. Supreme Court, April 27, 2010)
In a 5-3 decision, the U.S Supreme Court reversed the Second Circuit ruling that an arbitrator had an inherent right, pursuant to the Federal Arbitration Act, to force parties to class arbitration even if they did not agreed to such an authorization. In analyzing the FAA, the majority concluded that "a party may not be compelled … to submit to class arbitration unless there is a contractual basis for concluding that the party agreed to do so." As a result, the arbitrators' award was made in "manifest disregard of the law."
Interesting decision which may have ended the minority opinion on "manifest disregard" standard used by the Second Circuit.
A copy of the decision can be found: here
Jeffrey L. Kingsley