Final Award Does Not Mean Revised Final Award.

In an underlying arbitration proceeding, the arbitrator initially issued a “Final Award” denying a request for an award of attorney fees by one of the parties. The arbitrator later modified the Final Award to include a fee award, and issued a “Revised Final Award.” The trial court confirmed the Revised Final Award. In reversing, the appellate court noted that under Code of Civil Procedure section 1284, an arbitrator may not reconsider the merits of the original award and make a new award under the guise of correcting the award. The matter was remanded for the trial court to strike the attorney fee award.  (Cooper v. Lavely & Singer (Cal. App. Second Dist., Div. 4; September 26, 2014) 230 Cal.App.4th 1, [178 Cal.Rptr.3d 322].)