Laughon

I. INTRODUCTION

Defendant and appellant Charlotte Laughon appeals from a trial court order confirming an arbitration award in favor of plaintiff and respondent International Alliance of Theatrical Stage Employees and Moving Picture Machine Operators of the United States and Canada, Local Union No. 16 (Local 16). Laughon argues that the trial court was required to vacate the arbitration award because the arbitrator failed to disclose (1) prior service as a neutral arbitrator in collective bargaining cases in which attorneys for Local 16 represented a party and (2) prior service as a neutral arbitrator in a non-collective-bargaining case in which attorneys for Local 16 represented a party. We conclude that, pursuant to Code of Civil Procedure, section 1281.9, subdivision (a)(4), the arbitrator was required to disclose his service as a neutral arbitrator in the non-collective-bargaining matter. We also conclude this claim was not waived and, therefore, the arbitrator’s nondisclosure of this required matter was grounds for vacation under section 1286.2, subdivision (a)(6)(A). For the parties’ guidance on remand, we find that the arbitrator was not required to disclose his…