In Britz, Inc. v. Alfa-Laval Food & Dairy Co. (1995) 34 Cal.App.4th 1085, a successful party to arbitration was held to be entitled to post-award, pre-judgment interest under Civil Code section 3287, subdivision (a). The Britz court held that the successful party was entitled to "recover damages certain" within the meaning of section 3287, subdivision (a) on the date the arbitrator rendered his award. (Britz, at p. 1106.) The court noted, "the arbitration award itself resulted in a new and fixed liability . Regardless of the individual elements that comprised that liability, respondents were entitled to payment of the fixed sum upon issuance of the award.. . . Although the interest was pre-'judicial judgment,' it was post-'contractual judgment.'" ( Id. at p. 1107.) The court held that "a trial court considering a petition to confirm or vacate an arbitration award is required to determine, de novo, whether the circumstances disclose a reasonable impression of arbitrator bias, when that issue is properly raised by a party to the arbitration." The court found it necessary "to remand the matter to the trial court for 'an evidentiary hearing at which the full extent and nature of the relationships at issue may be ascertained.' " (Ibid.)