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Stolt-Nielsen Societe Anonyme v. AnimalFeeds International Corporation

United States Court of Appeals for the Second Circuit

548 F.3d 85 (2008)

Relevant factsFree

AnimalFeeds (plaintiff) brought antitrust claims against Stolt-Nielsen (defendant), and a panel of arbitrators, addressing whether an ambiguous charter-party arbitration clause permitted class arbitration, ruled that it did, following similar rulings in other contract types. The district court vacated the award for manifest disregard of federal maritime law, reasoning the panel skipped a choice-of-law analysis that would have applied maritime custom-and-usage law barring class arbitration; AnimalFeeds appealed to the Second Circuit.

IssueFree

Whether a district court may vacate an arbitration award if there was a manifest disregard for the law by the arbitrators.

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