Does the due process clause in the 14th Amendment limit an arbitrator's award of punitive damages?

Travelers asserts that the due process clause of the 14th Amendment of the United States Constitution limits an arbitrator's award of punitive damages. In Shahinian v. Cedars-Sinai Medical Center (2011) 194 Cal.App.4th 987 (Shahinian), our colleagues in Division Eight of this district rejected an attack on an arbitrator's award of punitive damages, saying: "Here, the agreement gave the arbitrator broad authority to grant remedies available in court, and made no reference to punitive damages or to any limitation on the amount of such an award. If the punitive damages award was excessive, the arbitrator's error would be no different from other errors of law, which are generally not reviewable 'whether or not such error appears on the face of the award and causes substantial injustice to the parties.' . . . Moreover, where the arbitrator has made a legal error '"in either determining the appropriate law or applying it,"' the parties may obtain court review of the merits 'only if the arbitration agreement expressly provided that the

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