Defendant attorney appealed an order from the Superior Court of Los Angeles County (California), which confirmed an arbitration award in favor of plaintiff law firm, including punitive damages, in plaintiff’s suit for breach of contract. The trial court found that the arbitrator had not exceeded his powers in awarding punitive damages under Cal. Civ. Proc. Code § 1286.6(b), or under the Due Process Clause, U.S. Const. amend. XIV, § 1.

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Overview

Plaintiff law firm brought suit against defendant attorney for breach of contract in connection with the firm’s dissolution. The contract contained a broadly worded arbitration clause. The suit was stayed pending arbitration, where plaintiff was awarded compensatory damages, attorney fees, and punitive damages. The trial court confirmed the award and defendant appealed, contending that lack of judicial review of punitive damages violated his due process rights under U.S. Const. amend. XIV, § 1. The court, however, affirmed, finding that the arbitrator had not exceeded his powers under Cal. Civ. Proc. Code § 1286.6(b), that U.S. Const. amend. XIV, § 1, did not control private arbitration proceedings because they did not constitute state action, and that judicial enforcement of the arbitrator’s punitive damage award did not, as a matter of due process, need to include judicial review of the merits of the award. The court denied plaintiff’s request for sanctions but awarded plaintiff costs and attorney fees.

Outcome

The court affirmed the judgment confirming the arbitration award in favor of plaintiff law firm in its breach of contract suit against defendant attorney, and denied plaintiff’s request for sanctions but awarded plaintiff costs and attorney fees. The court held that lack of judicial review of punitive damages awarded in arbitration did not violate due process because the arbitrator’s ruling did not constitute state action.