NY Appellate Division, In Daesang v. NutraSweet, Delivers a Blow to “Manifest Disregard” Doctrine
Mealey’s International Arbitration Report
November 2018
Partner John Dellaportas authored the Mealey’s International Arbitration Report article “NY Appellate Division, In Daesang v. NutraSweet, Delivers a Blow to ‘Manifest Disregard’ Doctrine.” The article examines the New York State Appellate Division’s decision to reject a trial court’s invocation of the “manifest disregard of the law” doctrine to partially vacate an international arbitration award in Daesang v. NutraSweet. The decision was unanimously hailed by local practitioners but, at least on paper, if perhaps not in practice, the Appellate Division reaffirmed a somewhat looser standing for manifest disregard than the Second Circuit.