In Hall Street Associates, L.L.C. v. Mattel, Inc., 552 U.S. 576 (2008), the Supreme Court addressed the question of "whether statutory grounds found in 9 U.S.C. 10, 11 for prompt vacatur and modification may be supplemented by contract." 552 U.S. at 578. The Court first noted a circuit split on "the exclusiveness of these statutory grounds when parties take the FAA shortcut to confirm, vacate, or modify an award." Id. at 583. It then addressed the petitioner's contention that Wilko v. Swan, 346 U.S. 427 (1953), provided for "expandable judicial review authority" of arbitration awards, and in particular that Wilko established an independent "manifest disregard of the law" ground for vacatur of an arbitration award. Id. at 584-85. The Court was wholly unconvinced by this argument, stating that "this is too much for Wilko to bear," and that the manifest disregard of law language was perhaps "meant to name a new ground for review, but maybe it merely referred to the section 10 grounds collectively, rather than adding to them." Id. at 585 Alternatively, the Court stated that manifest disregard "may have been shorthand for section 10(a)(3) or section 10(a)(4), the paragraphs authorizing vacatur when the arbitrators were 'guilty of misconduct' or 'exceeded their powers.'" Id. The Court then turned to the statutory language of the FAA and applied canons of statutory interpretation to determine that "the text compels a reading of the sections 10 and 11 categories as exclusive." Id. at 586. However, the Court left open a potential avenue for judicial review beyond the FAA by stating that parties "may contemplate enforcement under state statutory or common law . . . where judicial review of different scope is arguable." Id. at 590.