605 (2010) ("We do not decide whether 'manifest disregard’ survives our decision in Hall Street [ ] as an independent ground for review or as a judicial gloss on the enumerated grounds for vacatur set forth at 9 U.S.C. § 10.”). 6 . On one hand, the Second and Ninth Circuits have held that manifest disregard survives Hall Street as a valid ground for vacatur, because arbitrators who exhibit manifest disregard for the law have "exceeded their powers” under 9 U.S.C. § 10(a)(4). Comedy Club Inc. v. Improv W. Assocs., 553 F.3d 1277, 1290 (9th Cir.2009); Stolt-Nielsen SA v. AnimalFeeds Int'l Corp., 548 F.3d 85, 93-95 (2d Cir.2008), overruled on other grounds,-U.S. -, 130 S.Ct. 1758, 176 L.Ed.2d 605 (2010); see also Coffee Beanery, Ltd. v. WW, L.L.C., 300 Fed.Áppx. 415, 418-19 (6th Cir.2008) (<HOLDING>). On the other hand, the Fifth and Eleventh
holding that unpublished opinions may be persuasive recognizing that an advisory opinion is one that offers an opinion on a moot issue holding in an unpublished opinion that manifest disregard survives hall street as a nonstatutory ground for vacatur holding that imputed political opinion is a protected ground recognizing the dol opinion letter as the source of the nonstatutory factor