A.M. Classic Construction, Inc. v. Tri-Build Development Co

In A.M. Classic Construction, Inc. v. Tri-Build Development Co. (1999) 70 Cal.App.4th 1470, a subcontractor working on a public elementary school fell into a contract dispute with the contractor and the city employing the contractor. (A.M. Classic, supra, 70 Cal.App.4th at pp. 1472-1473.) After the subcontractor sued the contractor and the city for damages, the matter was submitted to an arbitrator, whose decision awarded the subcontractor damages against the contractor, but did not resolve the dispute between the subcontractor and the city. (Ibid.) Prior to the award's confirmation, the subcontractor asked the arbitrator to amend the award. (Ibid.) The arbitrator issued an amended award, which contained a ruling in the subcontractor's favor against the city. (Id. at p. 1473.) In determining that the amended award had been properly confirmed, the appellate court in A.M. Classic noted that no statute authorizes arbitrators to make substantive amendments in awards. (A.M. Classic, supra, 70 Cal.App.4th at p. 1476.) Although Code of Civil Procedure section 1284 permits arbitrators to correct awards, corrections are limited to miscalculations of amounts, mistakes in the description of persons and property, and defects in the form of the award. (70 Cal.App.4th at p. 1476.) Pointing to the strong public policy favoring the final resolution of disputes through arbitration, the court concluded that substantive amendments were permissible under the conditions described above. (Id. at pp. 1476-1479.)