Month: August 2025

Arbitration, Automobiles, Nonsignatories: Cal Sup Ct Ruled Ford Could Not Arbitrate Via Dealer Arbitration Agreement With Customer

The Court Disapproved of Felisilda v. FCA US LLC (2020) To The Extent It Suggested Manufacturers Could Make Use Of Dealers' Arbitration Clauses.         An issue knocking about in California Courts of Appeal has been whether Ford Motor Company and other automobile manufacturers could piggyback off arbitration clauses found in the contracts between dealerships and […]

Settlement: Lack Of Judicial Evaluation Of Derivative Lawsuit Settlement Results In Reversal

August 19, 2025 · Settlement, Settlement Agreements

Judicial Review Of The Fairness Of A Derivative Lawsuit Settlement Is Much Like Review Of The Settlement Of A Class Action.         Norman v. Strateman, A170356 (1/3 6/20/25) (Petrou, Fujisaki, Rodriguez), involved a cryptocurrency exchange dispute requiring judicial approval of derivative settlements. Donald Norman, Patrick Strateman, and Amir Taaki established Intersango, a cryptocurrency exchange that […]

Arbitration, Unconscionability: Unconscionable Terms In Employment Agreement Vitiated Separate Arbitration Agreement

The Two Agreements Were Read Together As One Agreement.         In Silva v. Cross Country Healthcare, Inc., B337435 (2/5  6.13/25) (Hoffstadt, Moor, Kim), employees Isabel Silva, Alejandro Garcia, and Janai Velasco challenged their employer’s attempt to compel arbitration of their wage-and-hour and related claims. Each plaintiff had signed two agreements at hiring: (1) an Arbitration […]

Jurisdiction: International Shoe Test For Minimum Contacts Does Not Apply To Foreign State Entities That Agreed To Arbitrate

August 10, 2025 · Arbitration: Jurisdiction

A SCOTUS Case Of First Impression.         Our next case, a US Supreme Court case, shows that the Court can still issue unanimous opinions in cases that require the application of statutes and that are not politically polarizing.         In CC/Devas (Mauritius) Ltd. v. Antrix Corp. Ltd., No. 23-1201, 605 U.S. __ (6/5/25) (Justice Alito), […]

Unconscionability: Fourth Dist. Div. 3 Agrees Arbitration Agreement Was Procedurally and Substantively Unconscionable

The Opinion Applies Established California Unconscionability Law.         In Velarde v. Monroe Operations, LLC, 111 Cal.App.5th 1009 (4/3 6/6/25) (Sanchez, Moore, Motoike), the California Court of Appeal affirmed denial of a motion to compel arbitration. Newport Healthcare required new hire Karla Velarde to sign an arbitration agreement as a condition of employment, presenting it among […]

Waiver: Second Dist. Div. 5 Applies Quach Standard, Which Does Not Require A Finding Of Prejudice To Find A Waiver Of The Right To Arbitrate

August 10, 2025 · Arbitration: Waiver

Activities Inconsistent With Right To Arbitrate, Without Showing Of Prejudice, Is Sufficient To Find Waiver Of Right To Arbitrate.         In Hofer v. Boladian, 111 Cal. App. 5th 1 (2/5  5/9/25) (Hoffstadt, Moor, Kim), the Califo In Hofer v. Boladian, 111 Cal. App. 5th 1 (2/5  5/9/25) (Hoffstadt, Moor, Kim), the Cali rnia Court of Appeal applied the […]

Deadlines: Second Dist. Div. 7 Holds When Employer Fails To Pay Arb Fees In 30 Days, Employee May Withdraw And Proceed In Court

August 10, 2025 · Arbitration: Deadlines

Bright Line Still Applies To The Deadline Employers Have To Pay For Arbitration Cost Or Lose Ability To Arbitrate, But Wait For California Supreme Court Ruling.         In Mone Yvette Sanders v. Superior Court, 110 Cal.App.5th 1304 (2/7  5/6/25) (Feuer, Martinez, Stone), the court held Code Civ. Proc. § 1281.98 is not preempted by the FAA; […]

Consumers, Internet Commerce: Ninth Circuit Holds Sign-In Wrap Did Not Result In Binding Arbitration

Judge Ryan Nelson Writes Majority Opinion And Concurring Opinion.         In Godun v. JustAnswer LLC, No. 24-2095 (9th Cir. 4/15/24) (R. Nelson, Paez, Ikuta), plaintiffs alleged that JustAnswer deceptively enrolled them in costly recurring subscriptions after paying $1–$5 for answers online. JustAnswer moved to compel arbitration under Terms of Service containing an arbitration clause, arguing […]

Federal Arbitration Act, Jurisdiction: No Jurisdiction Under Diversity To Confirm A Zero Award

US Supreme Court Rule That One Cannot Look To Underlying Dispute To Establish Jurisdiction Compels Result.         "Vacating the district court’s order granting Tesla, Inc. and Elon Musk’s petition to confirm an arbitration award, the panel held that the district court lacked subject matter jurisdiction to confirm the award pursuant to Badgerow v. Walters, 596 […]