On October 5, 2009, the U.S. Supreme Court denied writs of certiorari in three cases that examined whether manifest disregard of the law remains a valid basis for challenging arbitration awards in light of the Court’s decision last year in Hall Street Associates, L.L.C. v. Mattel, Inc., 128 S.Ct. 1396 (2008).  See, e.g., Improv West Assoc., v. Comedy Club Inc., 2009 WL 1648924 (Oct. 5, 2009); Coffee Beanery, Ltd. v. WW, LLC, 2009 WL 1342336 (Oct. 5, 2009); Grain v. Trinity Health, 2009 WL 1421117 (Oct. 5, 2009).  Notably, in the first two of those cases, Improv West Assoc. and Coffee Beanery, the Ninth Circuit and the Sixth Circuit, respectively, found that manifest disregard of the law survives Hall Street.  As for Grain, which was decided by the Sixth Circuit after Coffee Beanery, the court applied existing precedent in holding that an arbitration award may not be modified based upon manifest disregard of the law, and simply noted that Hall Street may have cast some doubt on the continued vitality of this doctrine as a basis for vacating arbitral awards.