In the latest development in the dispute between Cardell Financial and Suchodolski Associates, the Second Circuit issued a summary order affirming the district court’s judgment confirming an arbitration award and injunctive relief in Cardell’s favor. (We earlier posted on this case at the district court-level on January 20, 2010.) The underlying dispute chiefly concerned two separate agreements: the first – a $12.8 million promissory note, the second – a nonrecourse stock pledge agreement. The district court determined that the arbitrator had not manifestly disregarded the law by, among other things, refusing to apply New York law. Suchodolski Associates appealed, asserting the same theory for overturning the award. The Second Circuit affirmed for substantially the same reasons stated by the district court. Cardell Fin. Corp. v. Suchodolski Associates, Inc., No. 10-226 (2d Cir. Feb. 9, 2011).