Author: calmediation

Arbitration/Disclosures/Vacatur: “Any Professional Relationship” Doesn’t Really Mean Any Professional Relationship With Party Is Basis To Disqualify Arbitrator

How About Two Years – Is Two Years Good For You?      Brothers appealed from a superior court order denying their petition to vacate several awards of an arbitrator with whom they were dissatisfied.  They contended the arbitrator failed to disclose his professional relationship with opposing party’s counsel.  In 2011, one of the appellants discovered […]

Ninth Circuit Punts On Existence Of Federal Mediation Privilege

Maricopa County Waived Argument That Evidence Admitted To Show Settlement Should Be Privileged Under Federal Law      87 Yard Punt . . .      In Wilcox v. Arpaio, No. 12-16418 (9th Cir. Feb. 2, 2014) (Tashima, Farris, Reinhardt), the Ninth Circuit avoids having to “determine whether a mediation privilege should be recognized under federal common […]

Miscellaneous Practice Tip: No Liens On Human Beings

May 30, 2014 · Miscellaneous

  Quotation of the day      I know, I know, this has nothing whatsoever to do with the subject of my blawg.  And yet I couldn’t resist passing on this tidbit to you from one of yesterday’s unpublished cases decided by our local Court of Appeal: “There is one matter that requires minor modification of […]

Reviews/Disclosures/Confidentiality: Articles Highlight Problems With Post-Award Investigation Unearthing Arbitrator’s Bias, and Problems With Holes In Mediation Confidentiality Privilege

Recommended Reading:      Post-Arbitral Award Investigation Of Bias.      Paul J. Dubow, an arbitrator and mediator in San Francisco, asks whether post-award investigation can vacate arbitration awards in “ADR Update”, California Litigation (Vol. 27, No. 1 2014), p. 37.  It is easy for an unhappy client’s attorney to do a Google search about an arbitrator […]

Arbitration/Standard of Review: Though Parties Expressly Agreed To Judicial Review Of Legal Error, Trial Court Declining To Consider Whether Arbitrator Committed Legal Error Did Not Err

  Review Of Legal Error Here Was Job For Court Of Appeal      Though an error in law or fact is not a basis for overturning an arbitrator’s award, in California, the parties by agreement can make the arbitrator’s award reviewable for legal error.  Here, the parties agreed that the award was to be reviewed […]

Arbitration/Appealability/Waiver/1281.2/Agents: Court Of Appeal Reverses Denial Of Petition To Compel Arbitration, Because Delay In Bringing Petition Did Not Result In Prejudice

  Also, California Code of Civil Procedure, Section 1281.2, Did Not Prevent Arbitration, Because Federal Arbitration Act Applied And Preempted State Provision      Defendants/appellants in the next case lost a petition to compel arbitration in the trial court. At first blush, they had waived their right to arbitrate, because they delayed bringing their motion to […]

Arbitration/Delegation: Trial Court Lacked Authority To Rule On Enforceability Of Arbitration Agreement, Because Authority To Do So Was Delegated To Arbitrator (Even Though Delegation Clause Was Procedurally Unconscionable)

May 16, 2014 · Arbitration: Delegation

Split Of Opinion In District Two Over Enforceability Of Delegation Clauses Poker game of construction workers at canteen, Shasta Dam.  Russell Lee, photographer.  1939.  Library of Congress.          When Lourdes Tiri, a cook fired by Lucky Chances, a card-club casino and restaurant, sued her employer, the employer petitioned to compel arbitration.  However, the trial court […]

Arbitration/Rules/Fees: Court Of Appeal Affirms Denial Of Request For Attorney’s Fees As AAA Rules Were Insufficient Basis For Fee Entitlement

AAA Clause Does Not Contain Required Prevailing Party Language Necessary For Fee Recover Under Civ. Code section 1717      In Fujian Peak Group, Inc. v. Huang, No. D063296 (4th Dist. Div. 1 May 15, 2014) (Huffman, McConnell, O’Rourke) (unpublished), defendant Huang was deleted from an arbitration award because he had neither been served nor had […]

Mandatory Fee Arbitration Act/Deadlines/Standard of Review

Failure To Observe 30-Day Deadline To File Rejection Or Request Trial Tubes Appeal     Rothman v. Deshay, Case No. B245075 (2nd Dist. Div. 4 May 13, 2014) (Epstein, Manella, Edmon) (unpublished) is a Court of Appeal case that has its genesis in mandatory fee arbitration between attorney Rothman and client Deshay.  Though unpublished, the case […]

Arbitration/Collateral Estoppel/Res Judicata: Second District, Division 2 Holds Arbitrator’s Findings Do Not Bar Indemnification Claims Against Third-Party Subcontractors, And Reverses Judgment

  An Exercise In Drawing Bright Lines      Home seller Reagan Silber sought indemnification from subcontractors after rather decisively losing an arbitration with a home buyer, who discovered extensive and undisclosed water intrusion in the Bel Air home.  “The groundskeeper recalled that, on one occasion, Silber had joked to him that the house was worth […]