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Part I of this article provides a brief overview of the reasoning behind the limited judicial review of an arbitral award. Part II describes the state action doctrine and explains how several courts have used the doctrine in order to apply due process protection to proceedings involving private actors. In particular, this section discusses several significant decisions that involve the issue of whether a court's confirmation of an arbitrator's award of punitive damages creates state action and requires the application of constitutional protections such as due process. This Note concludes that due to a leading decision by the Eleventh Circuit, it appears that confirmation is not enough to transform an arbitration award into state action. However, it is important to note that several courts who have reluctantly followed this decision have opined that it appears that state action does in fact occur in these situations. Therefore, this debate will likely continue until the Supreme Court settles the matter.