An arbitration award could not later be challenged on the ground that the arbitrator's former law firm had once represented some business entities affiliated with an arbitrating party where the arbitrator had no knowledge of that prior representation, the California Court of Appeal has ruled.
The arbitration occurred when Charles Pankow and Heidi Betz were unable to resolve a dispute concerning dissolution of their partnership. After the hearing, a panel of three arbitrators issued an award in favor of Pankow. Thereafter, Betz learned for the first time that the law firm at which one of the arbitrators had previously been a partner had represented 3 business entities with ties to Pankow, and that this representation occurred while the arbitrator was affiliated with the firm. Based on these facts, Betz sought to vacate the award.