In City of Wilmington v. AFSCME, the Court of Chancery recently ruled that it would not overturn the decision of an arbitrator, even if it disagreed with the arbitrator, as long as the decision was rational. At footnote 39, the court cited another Chancery Court decision for the standard of review which requires more than a “mere error of law or fact”. Rather, the award of an arbitrator must rise to the level of being “irrational” before a court will refuse to enforce it. See Falcon Steel Co., Inc. v. HCB Contractors, Inc., 1991 WL 50139 ( Del. Ch. April 4, 1991).