Attorney Gottesman observes a resistance in the lower federal courts to accept principles that the Supreme Court enunciated in Misco, the lower courts expansively applying the limited exceptions to the general enforceability of awards. He opines that exceptions to enforcement have become loopholes that should be made as narrow as possible. “Only bribery of the arbitrator and illegality should be grounds for refusing to enforce an arbitration award.”Attorney Irving asserts that, in view of Misco, arbitration awards have little chance of being set aside on public policy grounds, short of illegality; that, in general, management has little faith in arbitrators as a group; that arbitrators should be less concerned with enforceability of their awards and more concerned with their validity; that, in view of Misco, management will likely negotiate constraints on arbitrator’s jurisdiction. He views threat of judicial reversal as a “healthy check” on errant arbitrators.