California Mediation and Arbitration summarizes recent case applying California statute on arbitrator disclosure:
"Though Code of Civ. Proc., section 1281.9 requires disclosure of “any professional or significant personal relationship” [between arbitrator and party or lawyer], evolving case law doesn’t require disclosure of any professional relationship. Pointing to rules that are concerned about only two years of relationships (Ethics Stds., std. 7(d)(8)(A), Code of Civ. Proc., section 170.1(a)(2)), the Court concluded a five year old relationship did not need to be disclosed."