Vandenberg v. Superior Court (1999) 21 Cal.4th 815 nixes only nonmutual collateral estoppel from an arbitration award.  Here, the same parties to the arbitration award, or individuals in privity with them, raised the same issues that the arbitrator had adjudicated, in court in connection with a post-confirmation (and post appeal from the confirmation) motion to amend the judgment to add the individuals to the judgment as alter egos.  In that context, the arbitration award could properly be the basis for mutual collateral estoppel, barring the individuals from contesting the facts the arbitrator had found against their LLCs which were parties to the arbitration (in which the individuals participated and directed the LLCs’ defense).