Task: Wrong Candidate Generation
Input (English): Arbitrator manifestly disregarded the law in reaching h'er final decision. See Pl. Mot. at 20 n.16. She does so only in a footnote, however, and never affirmatively argues that “manifest disregard” is still a proper ground for vacatur in light of recent Supreme Court decisions. Id.; see also ARMA, S.R.O. v. BAE Sys. Overseas, Inc., 961 F.Supp.2d 245, 268 (D.D.C. 2013) (discussing Supreme Court’s equivocation in Hall Street Associates, 552 U.S. at 585, 128 S.Ct. 1396, on whether manifest disregard of law can be basis for vacatur of arbitral award). The Court thus considers the issue forfeited. Huntington v. Dep’t of Commerce, 234 F.Supp.3d 94, 101, 2017 WL 211301, at *4 (D.D.C. Jan. 18, 2017); Gold Reserve Inc. v. Bolivarian Republic of Venezuela, 146 F.Supp.3d 112, 126-27 (D.D.C. 2015) (<HOLDING>); see Hutchins v. District of Columbia, 188 
 Holding statements: (A) holding that the validity of a collateral waiver is a threshold issue (B) holding that the waiver in two previous contracts was insufficient to support waiver of the contract at issue in that appeal (C) holding that failure to raise issue at district court forecloses party from raising same issue on appeal (D) holding obliquely raising issue in footnote insufficient to surmount waiver threshold (E) holding that an argument raised only in a footnote of a brief is waived
Output (English): holding that an argument raised only in a footnote of a brief is waived