California, United States of America
The following excerpt is from Kelley v. Bredelis, 45 Cal.App.4th 1819, 53 Cal.Rptr.2d 536 (Cal. App. 1996):
As discussed above, the substance of the arbitration award, including the award of attorney fees pursuant to Civil Code section 1717, is not appealable. ( 1141.23.) The dissent thus errs in seeking to reverse the portion of the arbitration award that awards attorney fees pursuant to Civil Code section 1717. If plaintiffs disagreed with the award of attorney fees by the arbitrator, their only remedy was a trial de novo. (Dickens v. Lee, supra, 230 Cal.App.3d 985, 281 Cal.Rptr. 783.)
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