Dornbirer

I.

INTRODUCTION

Plaintiff Miriam M. Dornbirer appeals from a judgment of the trial court in favor of defendant Kaiser Foundation Health Plan, Inc. (Kaiser). After a neutral arbitrator ruled in favor of Kaiser on Dornbirer’s claim that Kaiser failed to notify her that she needed followup care following a mammogram in 2001, Dornbirer petitioned the trial court to correct or vacate the arbitration award. Dornbirer argued that the arbitrator failed to disclose all of the information he was required to disclose pursuant to statute, and that the incomplete disclosure provided grounds for vacating the arbitration award. The trial court denied Dornbirer’s petition.

On appeal, Dornbirer maintains that the arbitrator’s disclosure was fatally deficient under the statutory scheme. We conclude that although the arbitrator’s disclosure was incomplete, the arbitrator sufficiently disclosed existing grounds for disqualification by acknowledging a prior relationship with both Kaiser and Kaiser’s counsel, Lewis Brisbois Bisgaard & Smith (Lewis Brisbois), and disclosing that he had served as an arbitrator in a number of prior arbitrations involving Kaiser and Lewis Brisbois. The…