Procedural Posture Defendant, professional career consulting agency, challenged a judgment of the Superior Court of San Diego County (California), which confirmed an arbitration award in favor of plaintiff client.
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Overview Defendant, professional career consulting agency, argued that a judgment affirming an arbitration award should have been reversed because of the apparent bias of the arbitrator and that the award exceeded the jurisdiction conferred by the parties. The court held that it could only address the legal correctness of the award, and not its merits or the sufficiency of the evidence. The court found that there was no actual bias on the part of the arbitrator, and there was adequate support for the finding of no apparent bias. The court reversed an award of damages for emotional distress because it was beyond the scope of the arbitration agreement, which was limited to disputes over the contract between the parties. The court affirmed the award of costs to the American Arbitration Association because the substance of the award was proper, and the award could have been routed through plaintiff.
Outcome The court affirmed the judgment in part, but reversed an award for damages for emotional distress, because it was beyond the scope of plaintiff client's arbitration agreement, which was limited to disputes over the contract with defendant, professional career consulting agency.