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Sano v. Shockley CA4/3
An arbitrator awarded Devan Shockley $450,000 for breach of fiduciary duty and $6,798 for diversion of business based on findings that George Sano had set up a competing business in violation of their partnership agreement. Sano appeals from the judgment confirming the arbitrator’s award. He argues the arbitrator exceeded his powers because the award of $450,000 in damages for breach of fiduciary duty bore no rational relationship to the conduct constituting the breach.
Although we reject Shockley’s assertion that Sano waived his right to appeal, we affirm the judgment. There is no question the arbitrator had the power to award money damages. Sano’s argument that the arbitrator exceeded his authority in awarding $450,000 in damages for breach of fiduciary duty is tantamount to arguing the arbitrator committed an error of fact or law, which does not come within our limited scope of review.

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