Category: Arbitration: Standard of Review

Arbitration/Vacatur/Standard Of Review: Appellant, Who Failed To Appear At Arbitration, Failed To Show Sufficient Cause For Continuance

All Things Considered . . .      Appellant Akin’s opening brief stated:  “All things considered . . . it was assumed that the May 30th arbitration had been cancelled.”  The lesson of our next case is that one who fails to show up for a scheduled arbitration hearing had better dot i’s and cross […]

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 […]

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 Div. 4 May 13, 2014) (Epstein, Manella, Edmon) (unpublished) is a Court of Appeal case that has its genesis in mandatory fee arbitration between attorney Rothman and client Deshay.  Though unpublished, the case […]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/Vacatur/Standard of Review: Court of Appeal Rejects Contentions That Arbitration Award Against Attorney Must Be Overturned, And Affirms

  Standard of Review, As Well As JAMS Rules, Largely Determine The Outcome      As the Court of Appeal explains in the next case, “[w]e apply a highly deferential standard of review to the award itself, insofar as our inquiry encompasses the arbitrators’ resolution of questions of fact or law.”  Put even more succinctly, “it […]

Arbitration/Standard of Review: Second District, Division 1 Concludes Arbitrator’s Decision, Even If Wrong, Was An Unreviewable Error Of Law

And So The Court Ducks Having To Decide A “Close” Question      Our next case involves a dispute between minority and majority shareholders, and how to value the minority shares for purposes of a buyout by the majority.  Minority shareholders argued that the arbitrator should have valued the shares under Operation Agreement requiring appraisal “without […]

Arbitration/Waiver/Standard of Review: In Wrongful Death Action, Second District, Division 7 Upholds Trial Court’s Finding That Right To Arbitration Had Been Waived

Defendants Simply Could Not Overcome Substantial Evidence Standard      After their 52-year-old sibling died following bariatric surgery, plaintiffs sued surgery center defendants for wrongful death.  No, surgery center defendants did not immediately move to compel arbitration.  Instead, they demurred, they moved to change venue, they propounded discovery that plaintiffs answered, and they took three depositions. […]

Arbitration/Employment/Unconscionability/Severability/Review: Second Dist., Div. 2 Affirms Denial Of Employer’s Motion To Compel Arbitration – Lack Of Mutuality Is Key Here

  Also, Court Refuses To Sever Because Of Lack Of Mutuality      No sooner did I post about McElroy v. Tenet Healthcare Corporation, a case reversing an order denying arbitration to a healthcare organization sued by a nurse, than I came across our next case, decided on the same day, and affirming an order denying […]

Arbitration/Award: 9th Circuit Rules Decision Arbitrator Decision To Award Interest On Contract Damages Does Not Foreclose District Court From Awarding Interest On Remaining Portions Of Award

  Ninth Circuit Instructs District Court To Award Plaintiff/Appellant Interest On Non-Contract Damages In Arbitration Award      Above:  Frenchman’s Flat, Nevada.  Atomic cannon test. 1953.  Library of Congress.      Judge Duffy’s wry comment upfront signaled where the Ninth Circuit panel was going on this one:  “Lloyd’s pussyfooted for years only to eventually deny the claim […]

Arbitration/Employment/Waiver/Standard of Review: Fourth District, Division 1 Satisfied That Substantial Evidence Supports Finding Of Waiver Resulting From Delay And Considerable Discovery

Employer Didn’t Want To Arbitrate      Usually employees want their day in court, and employers try to arbitrate, but our next case presents “the unique situation where . . . the employer refuses to arbitrate, arguing the employee waived her contractual rights to arbitrate.”  The Court of Appeal had no difficulty satisfying itself that “substantial […]

Arbitration/Public Policy/Standard of Review: Licensing Requirement for Contractors Constitutes Explicit Legislative Expression of Public Policy, That If Not Enforced By Arbitrator, Constitutes Grounds for Judicial Review

Trial Court Must Conduct De Novo Review To Determine Whether Licensing Statute Requires Disgorgement of Compensation By Unlicensed Contractor      Our next case addresses an important exception to the general rule that an arbitrator’s award cannot be vacated because of an error of fact or law:  the “public policy exception.”      The setting is a […]