Case Citator › Frazier v. CitiFinancial Corp., LLC

Frazier v. CitiFinancial Corp., LLC

Is it still good law? What later courts have actually done to this case.

Declined by some courts
Court
Eleventh Circuit
Citation
604 F.3d 1313
Decided
Confirmed treatments
1
Flagged citations read
78 of 78
Treatment dates
2012
Declined by some courts
At least one reviewed court has declined to follow this case. No reviewed court has overruled it. A sister circuit declined to follow Frazier v. CitiFinancial Corp., LLC on manifest disregard of the law. The Fourth Circuit rejected Frazier's conclusion that this ground for vacating an arbitration award no longer exists after Hall Street.
More on how this was screened

All 78 flagged citations have been read, and the confirmed treatment is listed below. Later Eleventh Circuit opinions continue to follow Frazier.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

78 citations to Frazier v. CitiFinancial Corp., LLC sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Frazier v. CitiFinancial Corp., LLC?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Declined to follow

  • The Fourth Circuit declined to follow Frazier's conclusion that manifest disregard no longer provides a basis to vacate an arbitration award after Hall Street.

    Wachovia Securities, LLC v. Brand · Fourth Circuit · filed

    The Fifth and Eleventh Circuits have read Hall Street as holding that the common law standards are no longer valid grounds for vacatur because the FAA’s grounds are exclusive. Citigroup Global Mkts., Inc. v. Bacon, 562 F.3d 349, 358 (5th Cir. 2009); Frazier v. CitiFinancial Corp., 604 F.3d 1313, 1323-24 (11th Cir. 2010). ... Therefore, we decline to adopt the position of the Fifth and Eleventh Circuits that manifest disregard no longer exists.
    Read the full opinion on CourtListener →

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