Judge: Latrice A. G. Byrdsong, Case: 23STCP04285, Date: 2024-04-29 Tentative Ruling
Case Number: 23STCP04285 Hearing Date: April 29, 2024 Dept: 25
Hearing Date:
Monday, April 29, 2024
Case Name: Butler Law, PC v. Kimberly McDuff (King)
Case No.: 23STCP04285
Motion: Petition to Confirm Arbitration
Award
Moving Party: Petitioner Butler Law, PC
Responding Party: None
Notice: OK
Tentative Ruling: GRANT
Petition to Confirm Arbitration Award filed by Butler Law, PC.
Counsel for Petitioner is ordered to
serve and electronically file a proposed form of Judgment - consistent with this Court's Ruling - within 10-days of
this Court’s Order.
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BACKGROUND
Petitioner Butler Law, PC (“Petitioner”) filed the instant
petition to confirm attorney-client fee arbitration award issued by arbitrator S. Roger Rombro against Respondent Kimberly
McDuff (“Respondent”).
On March 8, 2024, the
Court continued the matter to April 29, 2024.
No opposition has been
filed as of April 24, 2024.
ANALYSIS
I. Legal Standard
“Any party to an
arbitration award in which an award has been made may petition the court to
confirm, correct, or vacate the award.” (Code Civ. Proc. § 1285.) “Regardless
of the particular relief granted, any arbitrator’s award is enforceable only
when confirmed as a judgment of the superior court.” (O’Hare v. Municipal
Resource Consultants (2003) 107 Cal.App.4th 267, 278.) “Once a petition to
confirm an award is filed, the superior court must select one of only four
courses of action: it may confirm the award, correct and confirm it, vacate it,
or dismiss the petition.” (EHM Productions, Inc. v. Starline Tours of
Hollywood, Inc. (2018) 21 Cal.App.5th 1058, 1063.) “It is well settled that
the scope of judicial review of arbitration awards is extremely narrow.” (California
Faculty Assn. v. Superior Court (1998) 63 Cal.App.4th 935, 943.) “Neither
the trial court, nor the appellate court, may ‘review the merits of the
dispute, the sufficiency of the evidence, or the arbitrator’s reasoning, nor
may we correct or review an award because of an arbitrator’s legal or factual
error, even if it appears on the award’s face.” (EHM Productions, supra,
at p. 1063-64.)
II. Discussion
A.
Filing Requirements (CCP § 1285.4) Satisfied
Code of Civil Procedure section 1285.4 states, “[a]
petition under this chapter shall: (a) Set forth the substance of or have
attached a copy of the agreement to arbitrate unless the petitioner denies the
existence of such an agreement. (b) Set forth the names of the arbitrators. (c)
Set forth or have attached a copy of the award and the written opinion of the
arbitrators, if any.”
Here,
Petitioner has satisfied the requirements of Code of
Civil Procedure section
1285.4 by setting forth the substance of the parties’ agreement to arbitrate
within the petition. (Pet., ¶ 2.) Petitioner sets forth the Arbitrator’s name,
S. Roger Rombro, and attaches a copy of the Arbitrator’s award of $18,773.71 in
Petitioner’s favor, signed and dated September 6, 2023. (Pet., ¶ 6; Attachment 6(c).) Respondent has not filed
any response requesting the Court to dismiss the petition or to confirm,
correct or vacate the award. Thus, the Court finds that Petitioner follows
section 1285.4.
B.
Service of the Arbitration Award &
Timeliness of Petition (CCP §§ 1283.6, 1288, 1288.4) Satisfied
Code of Civil
Procedure section 1283.6 states,“[t]he neutral arbitrator shall serve a
signed copy of the award on each party to the arbitration personally or by
registered or certified mail or as provided in the agreement.” (Code
Civ. Proc., § 1283.6.) Additionally, a party may seek a court judgment
confirming an arbitration award by filing and serving a petition no more than
four years, but not less than 10 days, after the award is served on the
petitioner. (Code Civ. Proc., §§ 1288, 1288.4.)
Here,
Petitioner has satisfied the requirement under section 1283.6 because it
provides the Court with a copy of the proof of service from the Arbitrator that
confirms that service was rendered on all parties on September 6, 2023. (Pet., ¶ 6; Attachment 6(c) POS.) Petitioner also
satisfied the timeliness requirement under sections 1288 and 1288.4 because the
petition was filed on November 22, 2023, which is more than 10 days, but less
than four years, after the Award was served.
C.
Service of the Petition, and Notice of
Hearing (CCP § 1290.4) Satisfied
Code of Civil Procedure, section 1290.4 states, in relevant
part:
(a)
A copy of the petition and a written notice of the time and
place of the hearing thereof and any other papers upon which the petition is
based shall be served in the manner provided in the arbitration agreement for
the service of such petition and notice.
(b)
If the arbitration agreement does not provide the manner in
which such service shall be made and the person upon whom service is to be made
has not previously appeared in the proceeding and has not previously been
served in accordance with this subdivision:
(1)
Service within this State shall be made in the manner
provided by law for the service of summons in an action.
(2)
Service outside this State shall be made by mailing the
copy of the petition and notice of hearing and other papers by registered or
certified mail. Personal service is the equivalent of such service by mail.
Proof of service by mail shall be made by affidavit showing such mailing
together with the return receipt of the United States Post Office bearing the
signature of the person on whom service was made…”
Here, the
Petitioner provides the Court with proofs of service, indicating that
Respondent was served with a copy of the petition as well as other documents
relevant to the petition and notice of the hearing. (12/12/23 POS; 3/26/24
POS.) Therefore, the Petitioner has satisfied section 1290.4.
CONCLUSION
Based on the foregoing, Petitioner’s unopposed Petition to Confirm
Arbitration Award is GRANTED.
Counsel for the Petitioner is ordered to serve and
electronically submit a proposed form of Judgment - consistent with this Court's Ruling - within 10-days of this
Court’s order.
Moving party is ordered to give notice.