Category: Arbitration: Section 1286.6 Correction by Court

Arbitration: Setoff In Arbitration Award That Affected 3d Party Could Not Be Corrected By Trial Court

Can A Merits Award In Arbitration That Affects Rights Of Third Party Who Did Not Participate In Arbitration Be Corrected?         The majority opinion in E-Commerce Lighting, Inc. v. E-Commerce Trade LLC, E074525 (4/1  12/9/22) (Raphael, Ramirez; dsst. Mentrez), answered the above question with a "no", reversing the trial judge. Judge Menetrez, dissenting, answered "yes," […]

Arbitration Awards: Time To Change “Award” And Add Attorneys Fees Did Not Expire, Because Award Was Not Final Award

This Case Is Must Reading For Determining Whether An Arbitrator's Ruling Is An Award.         "As this case highlights, whether an arbitrator's ruling constitutes an 'award' is a significant event." Lonky v. Patel, B295314 consolidated with B297632 (2/2  7/2/20) (Hoffstadt, Lui, Chavez). Indeed. The arbitrator can continue to issue interim rulings before there […]

Arbitration/Public Policy/Section 1281.2/Correction: Award Is Corrected Because Arbitrator Incorrectly Ruled That Plaintiff Breached Arbitration Agreement By Choosing To File A Lawsuit

Arbitrator Acted Beyond Powers Because Award Violated Party's Statutory Rights And Clearly Defined Public Policy.         Instead of initiating arbitration, a party subject to an arbitration agreement chooses to file a lawsuit when a dispute arises.  Has the party breached the arbitration agreement?  And if the arbitrator issues an award by holding […]

Arbitration: 1286.2 Vacatur, 1286.6 Correction By Court: Party Contending Trial Court Erred By Confirming Award Loses By Relying On Statutory Authority For Correcting An Award

Contention That There Was Error In  Confirming The Award Was Not Before The Court.      To quote the late Steve “The Crocodile Hunter” Irwin, “Crikey!”.      On appeal, defendant Porter argued that the arbitrator exceeded his authority, as a result of which confirmation of the arbitration award was error, citing Cal. Code Civ. Proc., section […]

Arbitration/Fees/Vacatur: Arbitrator Who Applies Statutory Definition of “Prevailing Party” To Award Fees Rather Than Contractual Definition Does Not Exceed His Powers

Court Does Not Decide Whether Contractual Provision Limiting Arbitrator’s Power To Apply Definition Of “Prevailing Party” Other Than Found In Agreement Would Be Unenforceable As Violative Of Public Policy.      Does an arbitrator who applies the statutory definition of “prevailing party” found in Civil Code Section 1717(b)(1), rather than than the definition the parties contractually […]

Arbitration/Deadlines/Correction: Arbitrator Did Not Exceed Powers By Awarding Post-Termination Royalties After License Agreement Ended And Appellant Missed Deadline To Seek Correction Of Award

Post-Termination Of License Royalties Were Part Of $128.3M Arbitration Award.      In Amkor Technology, Inc. v. Tessera, Inc., A139596 (1/3 Nov. 25, 2014) (Pollak, Siggins, Jenkins) (unpublished), the Court of Appeal affirmed part of a larger arbitration award for $128.3M.     Procedural hurdle.       Appellant Amkor stumbled on a procedural hurdle:  Its petition to correct […]

Arbitration/Public Policy/Correction Of Judgment: Policy Against Certain Fee Splitting Arrangements Does Not Justify Judicial Review Of Arbitration Award Enforcing Oral Fee Splitting Arrangement

Arbitrator Did Not Exceed His Powers By Enforcing Oral Fee Splitting Arrangement       Attorneys Cohen and Sheinkopf had an oral agreement to split client fees:  75% to Cohen, 25% to Sheinkopf.  After the two attorneys went their separate ways, they arbitrated a fee dispute in which the arbitrator enforced their oral fee splitting agreement, resulting […]

Arbitration/Correction of Award/1286.6: Arbitrator Did Not Exceed Her Powers In Calculating Damages, Where Appellant Was Ordered To Produce Documentation Of Manufacturing Costs And Failed To Do So

  Maxim of Equity:  “No one can take advantage of his own wrong.” (Civ. Code, section 3517).      Defendant/Appellant Donn Zellet appealed from a judgment confirming an arbitration award for $376,418 in damages, contending the arbitrator exceeded her powers in grossly miscalculating damages, and the superior court erred in not correcting the award.  Clark v. […]

Arbitration/Vacatur/Deadlines: Too Late To Correct Arbitrator’s Award In High-Low Arbitration, Appellant Could Still Enforce “High-Low” Limit To The Award With Motion Requiring A Satisfaction Of Judgment

Once Again, Fourth Appellate District Demonstrates That Often There’s More Than One Way To Skin A Cat Where Arbitration Deadlines Are Involved      Cats.  1927.  Library of Congress.      On April 4, 2014, we posted about the way a plaintiff found to get around a deadline in arbitration:  after the time ran out to modify […]

Arbitration/Deadline/Delegation/Vacatur: Fourth District, Div. 1 Affirms Trial Court’s Order Denying Plaintiffs’ Motion To Vacate Award Because Parties Agreed Arbitrators Could Decide Whether The Arbitration Was Timely — Or Not

Arbitrators Acted Within Their Powers, So It Didn’t Change Results Even If They Erred      In the underlying dispute, Plaintiffs obtained a substantial award of $150,000 compensatory and $302,784 in punitive damages, blown out when the Court of Appeal ruled that the dispute, related to lease provisions, was subject to arbitration.  Defendants then moved, successfully, […]