California, United States of America
The following excerpt is from Bergelectric Corp. v. MCB Joint Ventures, LLC, D070658 (Cal. App. 2017):
The arbitrator reasoned he could award attorney fees based on the interrelated nature of the parties' three contracts and the existence of an attorney fee provision in their Bonding and Accounts Payable Agreement. If the arbitrator erred in his analysis, he committed a legal and/or factual error not subject to judicial review, rather than an act exceeding his powers. (Moshonov v. Walsh (2000) 22 Cal.4th 771, 776 [where parties submitted the issue of attorney fees to the arbitrator and both prayed for fees, the arbitrator's decision was not subject to judicial review for error].)
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