Month: May 2012

Arbitration/Enforceability/Homeowners: CC&R Arbitration Provision Does Not Constitute Agreement To Arbitrate Between HOA and Developer

  But Arbitration Provision Between Developer and Direct, Original Purchasers, Suffices To Compel Arbitration of Those Purchasers’ Claims      Covenants, conditions and restrictions (CC&Rs) containing an arbitration provision often raise gnarly questions about enforceability. Is the provision enforceable, and if so, what group will be bound to arbitrate? Those issues were presented in the next […]

Arbitration/Employment/Unconscionability: First District, Division 3 Affirms Superior Court’s Refusal To Compel Arbitration Of Claims By Carpet Installers

The Arbitration Provision is Unconscionable, and Concepcion Does Not Change the Analysis      “Unconscionability” may sound like an abstract legal principle, but it usually entails a very fact-specific analysis.  Try out these facts:  plaintiffs are carpet layers; they speak Spanish; contracts were presented to them only in English; they have difficulty reading simple written English; […]

Mediation/Mediators: Paws for a Moment – Pet Mediators

May 5, 2012 · Mediation: Mediator

New Breed of Mediator Helps to Resolve Bones of Contention      Pet mediation is the subject of Veronica Dagher’s April 30, 2012 article in the venerable Wall Street Journal, entitled “A Dog’s Bark Is Better Than Litigation’s Bite.”       During my years as a litigator, I’ve actually encountered several acrimonious lawsuits involving dogs – one […]

Arbitration: Unconscionability/Enforceability: AT&T Mobility v. Concepcion Requires Reversal of Order That Found Arbitration Agreement Unenforceable – With Court of Appeal Expressing No Opinion On Enforceability

  Another Example of the Search for Wiggle Room Within the Concepcion Straightjacket      California courts necessarily follow the ruling of AT&T Mobility LLC v. Concepcion, __ U.S. __ , 131 S.Ct. 1740 (2011), overruling the holding of Discover Bank v. Superior Court, 36 Cal.4th 148 (2005) that in turn had held that class action […]

Miscellaneous: Is Bracketing Dead?

May 2, 2012 · Miscellaneous

Maybe Not, But Mediator Proposes Other Strategies      Mediator Robert Mann has an interesting article in the April 27, 2012 edition of the Los Angeles Daily Journal, under the heading, “Is bracketing dead?  New strategies for mediation.”  (Verdicts and Settlements section, p. 2).      “Bracketing” is the “dance of negotiation.”  Each side comes back repeatedly […]

Arbitration/Fees/Construction of Agreement: Broadly Worded Fee Provision, Including More Than Arbitration, Results in Reversal of Trial Court Order That Had Denied Fees to Prevailing Party

  “Dispute Resolution” Encompassed More Than Arbitration     Dispute resolution provisions in a contract often provide for attorney’s fees, and when they do, distinctions between such terms as "dispute resolution", "arbitration", "mediation", "lawsuit", and "legal proceeding" may become very significant. Such was the case in Toro Enterprises, Inc. v. Pavement Recycling Systems, Inc., Case No. […]