In Government of Guam v. Pacificare Health Insurance Co. of Micronesia, Inc., 2004 Guam 17, the Court established the relevant standard for evaluating manifest disregard of law claims. The Court stated that "manifest disregard of the law means something more than just an error in the law or a failure on the part of the arbitrators to understand or apply the law." Pacificare, 2004 Guam 17 47. To succeed on a manifest disregard of law claim, a party seeking vacation must show that "the error was obvious and capable of being readily and instantly perceived by the average person qualified to serve as an arbitrator," that the law disregarded was "well defined, explicit, and clearly applicable," and that the arbitrator chose to ignore this well-defined law. Id. 46. The Court made clear that judicial review under this standard is "extremely limited" and that the showing required is a "stringent test." Id. 46, 48.