In Citigroup Global Markets, Inc. v. Bacon, the United States Court of Appeal for the Fifth Circuit considered whether an arbitrator’s manifest disregard for the law was grounds for vacation of an arbitration award.  The Fifth Circuit held that it was not. An arbitration panel ordered Citigroup Global Markets to pay Debra Bacon $256,00.  Bacon’s husband had forged her signature to withdraw funds from her Citigroup Individual Retirement Accounts.  Bacon submitted a claim in arbitration seeking reimbursement for the unauthorized withdrawals and the panel awarded her $218,000 in damages and $38,000 in attorneys’ fees.