LEWCO IRON METALS, INC. v. Superior Court

Case law holds generally that, where one party to a multiparty judicial arbitration proceeding requests a trial de novo, the entire arbitration award is vacated and the whole case must be tried. A limited exception has been recognized, under which an award in favor of one party may stand despite a trial de novo request by another, where the two parties’ claims are legally and factually unrelated. We must decide whether that exception applies here. We conclude that, if the exception is valid at all in view of the governing statutes and court rules, it has no application in this case.

I

Procedural Background

Michael Dibble, Sr. (Father), and Michael Dibble, Jr. (Son), brought a combined action for wrongful death and personal injuries. Father’s wrongful death claim alleged his daughter, Victoria Dibble, died as a result of a collision between a vehicle in which she was a passenger and a truck owned and operated by defendants. Son’s personal injury claim alleged he also was a passenger in the vehicle and was injured as a result of the collision.

Concurrently, Son brought a separate action for wrongful death and personal injuries. Son’s wrongful death claim alleged his…