Synopsis By: Lurie - Proceeding Author:

Applying, literally, a state statutory definition of bias based upon nondisclosure, the California appellate court vacated an award by Arbitrator Kagel, even though no actual bias was shown. The Court made clear that its ruling would not apply to collective bargaining cases but Arbitrator Kagel advises that disclosure be made of prior services rendered as a neutral to the parties and their counsels.