Arbitration has become increasingly common because it is perceived to be a cheaper, less formal and faster method to resolve business disputes. Yet litigants and their lawyers have found ways to introduce into arbitrations many of the same complexities and delays that led to the disillusionment with the courts in the first place. A recent decision of the California Court of Appeal illustrates this trend. In Burlage v. Superior Court, the appellate court reversed an arbitrator's award on the ground that the arbitrator had failed to allow one side to introduce evidence that the court considered to be "material" to the case.