A court will vacate an arbitration award only upon proof of one or more of the grounds provided in Minn. Stat. Moreover, even if Minnesota recognized the doctrine, we would not vacate the award in this case. Manifest disregard of the law provides a narrow basis for vacating an arbitration award. Manifest disregard of the law is demonstrated where an arbitrator commits an error that is obvious and capable of being readily and instantly perceived by the average person qualified to serve as an arbitrator. The term disregard means the arbitrator appreciates the existence of a clearly governing legal principle but chooses to ignore it.
Manifest disregard is more than an error or misunderstanding of law.
The question before the arbitrator in this case was whether respondent properly reprimanded a police firearms instructor for violation of respondent s sexual harassment policy. Respondent s police department requires its police recruits to complete a two-week firearms course. The last two days of this course are spent conducting firearms qualifications tests. In September 1997, a police recruit made a sexual harassment complaint to the police department after the recruit failed her qualifications tests. The recruit complained that the instructor of her firearms course had initiated personal conversations with her and gave her extra attention during class.