Judge: Mark V. Mooney, Case: 22STCP02586, Date: 2022-10-12 Tentative Ruling

Case Number: 22STCP02586    Hearing Date: October 12, 2022    Dept: 68

TENTATIVE RULING:

PETITION OF NOBLE HOUSE TO CORRECT OR VACATE THE ARBITRATION AWARD:  DENIED

 

PETITION OF CRI TO CONFIRM THE ARBITRATION AWARD: GRANTED

 

DISCUSSION

At issue in these two competing petitions is whether the award of attorney fees by the arbitrator can be upheld on review.

Legal Standard

“The scope of judicial review of arbitration awards is extremely narrow. Courts may not review the merits of the controversy, the sufficiency of the evidence supporting the award, or the validity of the arbitrator's reasoning.... Indeed, with limited exceptions, ‘an arbitrator's decision is not generally reviewable for errors of fact or law, whether or not such error appears on the face of the award and causes substantial injustice to the parties.’”  (Dept. of Personnel Admin. v. Cal. Correctional Peace Officers Ass'n (2007) 152 Cal.App.4th 1193, 1200. Accord California School Employees Assn. v. Bonita Unif. School Dist. (2008) 163 Cal.App.4th 387, 406-07.) The only grounds for judicial review of an arbitration award are:  “(a) the award was procured by corruption, fraud or other means; (b) there was corruption in the arbitrator; (c) the rights of the party were substantially prejudiced by misconduct of a neutral arbitrator; (d) the arbitrator exceeded … powers and the award cannot be corrected without affecting the merits of the decision upon the controversy submitted; (e) the rights of the party were substantially prejudiced by the refusal of the arbitrator to postpone the hearing; or (f) there was a disclosure or disqualification issue….” (Allstate Ins. Co. v. Sup. Ct. (2006) 142 Cal.App.4th 356, 362-63 (citing, e.g., CCP §1286.2); SWAB Financial v. E*Trade Securities (2007) 150 Cal.App.4th 1181, 1201.) Arbitration is a private arrangement whereby the parties have bargained for an arbitrator to exercise his or her “flexibility, creativity, and sense of fairness” in selecting a particular remedy. Advanced Micro Devices, Inc. v. Intel Corp. (1994) 9 Cal.Rptr.2d 581. However, arbitrators are constrained by the bounds of the arbitration agreement and a party may successfully challenge an arbitration award if the relief granted was in violation of specific restrictions in the arbitration agreement. Id.

Analysis

            The Court grants CRI’s motion to confirm the arbitration award and denies Noble House’s motion to vacate or correct the award. The arbitrator’s decision was rationally based on CA caselaw and did not result in substantial injustice to Noble House.

It was Reasonable for the Arbitrator to Conclude that the SRA Provided for Attorney Fees

            Given the strong deference owed to the arbitrator on determinations of fact and law, the court finds that section 9 of the SRA can reasonably be construed as an attorney fees provision. Therefore, the court disagrees with Noble House that the SRA did not contain an attorney fees provision.

Here, the provisions at issue are reproduced below:

9. Indemnification.

9.1 Distributor shall defend, indemnify and hold harmless the Representative from and against any loss, liability, claim or damage (including reasonable attorney’s fees and costs) relating to or arising from a willful breach of this Agreement by Distributor.

9.2 The Representative shall defend, indemnify and hold harmless Distributor, its officers, directors, members, employees and agents from and against any loss, liability, claim or damage (including reasonable attorney’s fees and costs) relating to or arising from (i) any claim or allegation in connection with the marketing of the Products by the Representative and (ii) a breach of this Agreement by the Representative.

9.3 The foregoing indemnities are conditioned on (i) prompt written notice by the party seeking indemnification; (ii) cooperation in the defense of the claim, demand or action; and (iii) the obtaining of the prior written approval of the indemnifying party of any settlement or offer of settlement.

Noble House argues that section 9 of the SRA cannot be construed as anything other than a third-party indemnification provision. Noble House argues that 9.1 and 9.2 are inoperative if the requirements in 9.3 are not met. Moreover, it contends, 9.3 would have a muddled meaning if it were construed to apply to anything other than third-party claims. On the other hand, CRI argues that the mere mention of indemnification in 9.3 does not limit section 9 to third 3rd party indemnification. Further, it argues, the language in section 9 is much broader than typical 3rd party indemnification provisions.

Noble House argues that Alki Partners, LP v. DB Fund Services, LLC supports its proposition that section 9 of the SRA cannot be construed as an attorney fees clause. In Alki Partners, the court held that generally, if the clauses surrounding the disputed clause describe third party liability, the disputed provision will be deemed a third-party indemnification provision. Alki Partners, LP v. DB Fund Services, LLC (2016) 4 Cal.App.4th 14, 20.

Here, unlike surrounding provisions at issue in Alki Partners, section 9 does not limit itself to third-party indemnification. In fact, as evidenced by sections 9.1 and 9.2, section 9 explicitly contemplate actions between CRI and Noble House arising out of breach of the SRA. Specifically, section 9.1 states that the “Distributor shall… indemnify the Representative from any… damage (including reasonable attorney’s fees and costs) relating to or arising from a willful breach of this Agreement by Distributor.” (supra.). This language contemplates the exact situation that unfolded between Noble House and CRI. Noble House was found to have willfully breached the SRA and CRI incurred damages including attorney’s fees and costs relating to or arising out of that breach. Therefore, the arbitrator’s interpretation of section 9 of the SRA was reasonable.

Notice of Intent to Seek Attorney Fees was Proper

            Noble House argues that CRI did not adhere to the strict 90-day notice requirement contained in ADR Rule 6 because CRI did not give notice that it was seeking attorney fees based on breach of the SRA until five months after the November 15-17, 2021 arbitration hearing (NH Memorandum of Points and Authorities pg. 6 lines 2-5.). On the other hand, CRI argues that it notified Noble House that it was seeking attorney fees as early as August 31, 2020 in both its demand for arbitration and its arbitration statement. However, Noble House argues that notice was improper and misleading because it was filed concurrently with an arbitration statement in which CRI indicated that was seeking attorney fees pursuant to causes of action unrelated to the contract theories it eventually prevailed on (NH Memo pg. 8 lines 12-29.). In this arbitration statement, CRI did not request attorney fees for its contract-related causes of action.

            Noble House analogizes to Emerald Aero, in which the court held an arbitration award was invalid because the party that received the award did not request relief in a timely manner. Emerald Aero, 9 Cal App. 5th at 1140. There, despite the applicable rules requiring advance notice to the other side at least 14 days before the hearing, the claimant gave notice just one day ahead of intent to seek punitive damages. Id. Along with giving last minute notice of intent to seek punitive damages, the claimant had repeatedly and egregiously failed to provide proper notice throughout the case on numerous other issues. Id. Conducting a totality of the circumstances analysis, the Emerald Aero court found this pattern of failing to provide notice “particularly troubling.” Id. at 1143.

            Here, unlike in Emerald Aero, the allegation that notice is improper is solely because the initial notice of intent to seek attorney fees contained some ambiguity around whether CRI was generally seeking attorney fees or seeking them only for certain causes of action. This isolated ambiguity alone is not enough to overrule the arbitrator’s finding that by checking the attorney fees boxes on the demand for arbitration and the arbitration statement more than one year before the arbitration hearing, CRI provided Noble House with adequate notice of intent to seek attorney fees.

CONCLUSION

            The arbitrator reasonably concluded that 1) the SRA contained an attorney fees provision in the event of breach of the SRA and 2) that CRI gave adequate notice of intent to seek attorney fees. Given the strong deference accorded to arbitrators in California, the court grants CRI’s motion to confirm the Award and denies Noble House’s motion to correct or vacate the Award.