'Manifest Disregard' Not a Ground for Vacatur under N.Y. Convention, Judge Rules

WILMINGTON, Del. - A Delaware federal judge has confirmed a $7 million arbitration award issued in favor of an Italian company, ruling that the arbitrator's alleged "manifest disregard of the law" does not justify vacatur under the Convention on the Recognition and Enforcement of Foreign Arbitral Awards. SEI Societa Esplosivi Industriali SpA v. L-3 Fuzing and Ordnance Systems Inc., No. 11-149 (D. Del.).

On Feb. 17, Judge Richard G. Andrews of the U.S. District Court for the District of Delaware explained that courts may not refuse to enforce an award due to an error of fact or law by the …