In Landis v. Pinkertons, Inc. (2004) 122 Cal.App.4th 985, the arbitrator's award accorded the plaintiff damages of various kinds, including damages for emotional distress. (Landis, supra, 122 Cal.App.4th at p. 988.) Prior to the award's confirmation, a defendant asked the arbitrator to strike the portion of the award granting damages for emotional distress, arguing that the plaintiff had not requested such damages, and that the plaintiff could not recover them for his claims. (Id. at p. 988.) The arbitrator granted the request, but the trial court confirmed the original award. (Id. at pp. 988-989.) The appellate court affirmed, reasoning that the modified award fell outside the nonstatutory amendment doctrine because the modification to the award did not "add a ruling on an issue submitted for decision but not addressed in the original award." (Id. at p. 992.)