Chael Clark of Carlton Fields has authored this article, available in JD Supra, discussing the Southern District’s decision in Copragri S.A. v. Agribusiness United DMCC. As the article explains, [t]he court held that because Copragri was not a party to the bill of lading and therefore did not consent to arbitration in New York, the arbitration panel acted outside its scope and authority when issuing its award.” Moreover, “the arbitration panel’s failure to analyze or even address Copragri’s various objections … constituted a manifest disregard for the law, further justifying vacatur.”
Those interested in additional insight into the court’s decision, especially as it relates to the ongoing vitality of the manifest disregard decision, should take a look at Dave Reif’s article discussing Copragi.
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