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Georgia's Recent Amendment of its Arbitration Code to Allow Arbitration Awards to be Vacated on the Basis of Manifest Disregard of the Law May Signal that Other States Will Follow

Georgia House Bill No. 792, which allows an arbitration award under the Georgia Arbitration Code to be vacated upon a showing of the arbitrator's "manifest disregard of the law," was signed into law on June 4, 2003 by Governor Perdue.1 This enactment overturns the recent Georgia Supreme Court decision of Progressive Data Systems, Inc. v. Jefferson Randolph Corp., 275 Ga. 420, 568 S.E.2d 474 (2002), and makes Georgia the first jurisdiction to codify "manifest disregard of the law" as a statutory ground for vacatur.

Background of the Legislation

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