California Court's Authority to Overturn Arbitration Awards

In Advanced Micro Devices, Inc. v. Intel Corp. (1994) 9 Cal. 4th 362 36 Cal. Rptr. 2d 581, 885 P.2d 994 the Supreme Court delineated "the standard for measuring the scope of the arbitrators' authority." (Id. at p. 366.) There the high court held "the deference due an arbitrator's decision on the merits of the controversy requires a court to refrain from substituting its judgment for the arbitrator's in determining the contractual scope of those powers." (Id. at p. 372.) However, courts retain the authority to overturn arbitration awards "as beyond the arbitrator's powers, whether for an unauthorized remedy or a decision on an unsubmitted issue." (Id. at p. 375; see also Board of Education v. Round Valley Teachers Assn. (1996) 13 Cal. 4th 269, 275 52 Cal. Rptr. 2d 115, 914 P.2d 193.)