Alexander

The Code of Civil Procedure empowers arbitrators in certain cases to impose the discovery sanctions available in superior court. In this case, we hold that an arbitrator’s refusal to impose a discovery sanction provides no ground to vacate the arbitration award, even if the sanction is mandatory under the discovery statutes.

Maureen H. Alexander appeals from a judgment confirming an arbitration award in favor of Blue Cross of California (Blue Cross). Alexander contends the award should have been vacated because the arbitrator exceeded his powers by refusing to deem that Blue Cross had admitted requests for admissions to which it failed to respond. In the published part of our opinion, we reject that argument. In the unpublished part of the opinion, we conclude we are bound by the trial court’s factual findings that Blue Cross did not engage in misconduct during arbitration, and that the arbitrator was not biased against Alexander. Consequently, we affirm the judgment.

Background

Viewing the evidence in the light most favorable to the judgment confirming the arbitration award, as we must (Siegel v. Prudential Ins. Co. (1998) 67 Cal.App.4th 1270, 1273 [ 79 Cal.Rptr.2d…