When Can an Arbitration Award Be Overturned? What the Supreme Court's Lindell Decision Means
Moving Forward: Arbitration provides the certainty businesses need to resolve disputes and return focus to what matters most.
A recent Supreme Court decision left key questions unanswered—but reinforced why arbitration remains a reliable path to resolution for disputes.
If you've ever considered arbitration as a way to resolve a business dispute, you may have wondered:
What happens if the arbitrator gets the law wrong? Can a court overturn the decision?
That question was at the center of a recent, high-profile case involving MyPillow CEO Mike Lindell and a $5 million arbitration award. In January 2026, the U.S. Supreme Court declined to hear the case, leaving an important—but often misunderstood—area of arbitration law unchanged. Zeidman v. Lindell Mgmt. LLC, No. 25-504 (Jan. 12, 2026).
While the headlines focused on the personalities involved, the decision offers valuable guidance for businesses and individuals embarking on arbitration.
The Short Answer
Courts rarely overturn arbitration awards—even when they disagree with the arbitrator's legal reasoning.
That limited court review is not a flaw in arbitration. It is one of the key reasons parties choose it.
Understanding why requires a closer look at what happened in the Lindell case and what the law actually allows courts to review.
What Happened in the Lindell Arbitration?
The dispute arose from a public contest offering $5 million to anyone who could prove that certain data claimed to show election interference was not authentic election data.
A software developer reviewed the data and concluded it was not valid election information. When contest officials denied his claim, he filed for arbitration under the contest rules.
After a three-day hearing, a unanimous arbitration panel ruled in the software developer’s favor and awarded him the $5 million prize. A federal trial court later confirmed the award.
However, on appeal, the Eighth Circuit Court of Appeals vacated the award. Zeidman v. Lindell Mgmt. LLC, 145 F.4th 820 (8th Cir. 2025). The appellate court concluded that the arbitration panel had gone beyond the contract's written terms by relying on requirements that were not stated in the agreement itself.
The court ruled that the arbitrators had exceeded their authority—one of the limited grounds that federal law allows courts to review.
The developer then asked the U.S. Supreme Court to step in and clarify a related legal issue known as "manifest disregard of the law." The Court declined to hear the case, leaving the existing rules unchanged.
What Does "Manifest Disregard of the Law" Mean?
Despite how technical it sounds, the idea is fairly simple.
Manifest disregard of the law does not mean the arbitrator made a mistake.
It does not mean the arbitrator misunderstood the law or reached a decision a judge might not agree with.
Instead, courts that recognize this doctrine require proof that:
The law was clear and well-established
The arbitrator knew the law applied
The arbitrator intentionally refused to follow it
In other words, it addresses situations where an arbitrator knowingly ignores the law—not where the arbitrator interprets it incorrectly.
That is an extremely high standard, which is why successful challenges are rare.
Arbitration Finality: Understanding when courts can—and cannot—overturn arbitration awards helps Colorado businesses choose the right dispute resolution path.
Why Arbitration Decisions Are Hard to Overturn
Under the Federal Arbitration Act, courts may vacate an arbitration award only in limited circumstances, such as:
Fraud or corruption
Arbitrator bias
Serious misconduct during the hearing, such as refusing to hear material evidence
Arbitrators exceeding their authority under the contract
Courts are not permitted to re-try the case, re-weigh evidence, or substitute their own judgment for the arbitrator's.
Even serious legal or factual errors usually are not enough.
This limited review is intentional. Arbitration is designed to provide:
Faster resolution
Lower cost than litigation
Privacy
Finality
Without finality, arbitration would begin to look a lot like court—defeating its purpose.
Why the Law Is Still Unsettled
In a 2008 decision, the Supreme Court ruled that the Federal Arbitration Act provides the exclusive grounds for overturning arbitration awards. After that decision, federal courts split on whether "manifest disregard of the law" still exists as a separate basis for challenging awards.
Today:
Some federal courts recognize it in a very narrow form
Others reject it entirely
The Supreme Court has not resolved that split, including in the Lindell case.
What This Means for Colorado
Colorado is part of the Tenth Circuit, which continues to recognize manifest disregard—but only in a very limited way.
That means:
The doctrine technically exists here
Successful challenges remain extremely rare
Courts require clear proof that an arbitrator knowingly ignored controlling law
For practical purposes, arbitration awards in Colorado are generally final.
What Parties Should Take Away From This Case
Arbitration Is Final by Design
Unlike lawsuits, arbitration does not offer multiple layers of appeal. That certainty allows businesses and individuals to move forward rather than remaining tied up in years of litigation.
The Front-End Decisions Matter Most
Because court review is limited, the choices made before arbitration begins carry enormous weight:
How the arbitration clause is written
Which rules apply
Where the arbitration is seated
Who serves as arbitrator
Arbitrator Selection Is Critical
The Lindell case ultimately turned on how the contract was interpreted.
An arbitrator's experience, legal discipline, and understanding of contract law directly affect both the quality of the decision and its ability to withstand court review.
How Rocky Mountain ADR Approaches Arbitration
At Rocky Mountain ADR, we approach arbitration with a disciplined focus on the legal framework that supports enforceable awards.
This includes:
Identifying and applying the governing law chosen by the parties
Interpreting contracts according to their plain language
Conducting proceedings consistent with federal and state arbitration statutes
This approach supports arbitration's central purpose: providing efficient, fair, and legally sound resolution.
When parties trust that the process will be grounded in applicable law, they can participate with confidence—knowing the result is well-positioned for confirmation and enforcement.
Final Thoughts
The Supreme Court's decision not to hear the Lindell case did not weaken arbitration. Instead, it reaffirmed what arbitration has always offered:
Finality by design
Limited judicial review
Dependence on careful preparation and neutral selection
For Colorado businesses and individuals facing disputes, arbitration remains a powerful alternative to litigation—particularly when efficiency, privacy, and closure matter.
And when preserving relationships is a priority, mediation may provide an even more collaborative path forward.
Choosing the right process—and the right neutral—can make all the difference.
Frequently Asked Questions
Can arbitration awards be appealed?
Not in the traditional sense. Courts can only review arbitration awards on very narrow grounds—like fraud, bias, or the arbitrator exceeding their authority. Disagreeing with the decision is not enough to overturn it.
What is "manifest disregard of the law"?
It's a legal term for situations where an arbitrator knew what the law required and intentionally refused to follow it. It does not apply when an arbitrator simply interprets the law differently than a court might.
How often are arbitration awards overturned?
Successful challenges are uncommon. Courts confirm the vast majority of arbitration awards.
Does Colorado recognize manifest disregard?
Yes, but in a very limited form. Colorado is in the Tenth Circuit, which allows this type of challenge—but requires strong proof that the arbitrator knowingly ignored the law.
Considering arbitration or mediation for an upcoming dispute? Contact Rocky Mountain ADR to discuss which process may be appropriate for your situation.
Jennifer Arnett, Esq.
Rocky Mountain ADR
Denver, CO
720-726-5852
jennifer@RockyMtnADR.com
www.RockyMtnADR.com
This article is provided for general informational purposes only and is not legal advice. Every dispute is unique, and outcomes depend on specific facts and circumstances.
Jennifer Arnett, Esq., is the founder of Rocky Mountain ADR and brings nearly 25 years of legal experience to her mediation and arbitration practice. She is an AAA IDCR Panel Member and specializes in construction, insurance, commercial, and outdoor recreation disputes throughout Colorado.
