In Rifkind & Sterling, Inc. v. Rifkind (1994) 28 Cal. App. 4th 1282, the court stressed the private nature of these proceedings in affirming a punitive damage award assessed in a contractual arbitration between sophisticated business people. The constitutional requirement of postjudgment judicial review of punitive awards did not apply because "the arbitration in this case . . . was not state action. It was a private proceeding, arranged by contract, without legal compulsion. It was intended to provide a simple, final dispute resolution mechanism, independent of legal or court proceedings . . . ." ( Id. at p. 1291.)