Even if an arbitrator misapplies the law, courts are very reluctant to overturn arbitrators’ awards. An arbitrator in Pennsylvania thought that a pervasive hostile work environment required daily offensive behavior. The fact that a woman was asked for a one night stand, subjected to multiple vulgar and sexually suggestive comments about her body, asked about sexual relations with her fiancéé and grabbed by her supervisor who then peered down her blouse did not create a pervasive sexually hostile work environment in the mind of the arbitrator. Because there was no manifest disregard for the law, a federal district court judge would not overrule the arbitrator.
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