Two recent articles have been published regarding the evolving circuit split as to whether the “manifest disregard of the law” standard of review of arbitration awards survives the Supreme Court’s 2008 decision in Hall Street.  Each article offers a different framework in which to analyze Hall Street and its impact on the manifest disregard standard of vacatur, and suggests a way to resolve the circuit split.  Hiro Aragaki, Assistant Professor of Legal & Ethical Studies at Fordham’s Graduate School of Business, has published an essay entitled The Mess of Manifest Disregard in YLJ Online, the on-line companion to the Yale Law Journal (formerly called The Pocket Part), in which he argues that both sides of the circuit split have misread Hall Street and that the decision says nothing about the continued vitality of manifest disregard.   I recently published an article in the Securities Regulation Law Journal on the same topic, in which I argue that the Second, Sixth and Ninth Circuits’ approach correctly interprets Hall Street.   See Jill I. Gross, Hall Street Blues: The Uncertain Future of Manifest Disregard, 37 Secs. Reg. L. J. 232 (2009).  We eagerly await the Court’s next opportunity to address this issue.