The Committee on International Commercial Disputes of the New York City Bar Association issued a detailed report, The “Manifest Disregard of Law” Doctrine and International Arbitration in New York.  The Committee found that “the manifest disregard doctrine has been applied sparingly, especially so in the context of international awards challenged in New York state and federal courts,” and that “no international arbitral award rendered in New York has ever been set aside in the Second Circuit on the ground of manifest disregard.”