Compeer Financial, ACA v. Corp. Amer. Lending, Inc.
Split Score
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Case Summary
Disposition
Affirmed
The Eighth Circuit affirmed the district court’s confirmation of an arbitration award and appointment of a receiver in a contract dispute between Compeer Financial and Corporate America Lending (CAL) over $58 million in loan-payoff proceeds. The court held that the Phase I arbitration award was final and confirmable and that appointing a receiver was justified due to CAL’s repeated non-compliance and risk of asset dissipation.
Circuit Split Identified
Legal Issue
Whether, after Hall Street Assocs. v. Mattel, the Federal Arbitration Act allows courts to vacate arbitration awards on non-statutory grounds such as a "public-policy" or "manifest-disregard" exception.
Circuit Positions
Non-statutory grounds (public-policy / manifest-disregard) remain viable after Hall Street.
Hall Street makes FAA statutory grounds exclusive; courts may not rely on public-policy or manifest-disregard exceptions.
Issue unresolved / no binding position yet taken.
Conflict Summary
Some circuits continue to permit vacatur of arbitration awards on public-policy or manifest-disregard grounds despite Hall Street’s statement that FAA §§ 10–11 are exclusive, while other circuits hold that Hall Street abolishes all non-statutory bases for vacatur.