Author: calmediation

Section 998 Settlement Offers: Different Code Provisions Govern Post-Judgment Fees And Costs

This Case Involves The (Non) Application Of Civil Code § 998 To Postjudgment Fees And Costs.         The plaintiff, Caesar Elmi, rejected a settlement offer made by the defendant, Related Management Company, pursuant to section 998. The case was later resolved for an amount lower than what was offered, leading to a limitation on Elmi’s […]

Gateway Issues: JAMS’ Consolidation Of Arbitration Claims Did Not Present Gateway Issue Of Arbitrability

Plaintiff Was Not Harmed Because Defendant Had Not Refused To Arbitrate, And Questioned Consolidation Of Claims Could Still Be Addressed By Arbitrator.         Kiana Jones sued Starz Entertainment, LLC, claiming violations of federal and state privacy laws after Starz allegedly disclosed her identity and video viewing history to third parties. Jones initiated arbitration proceedings under […]

Enforceability Of Arbitration Agreement On Internet: 9th Circuit Agrees Terms Were Not Conspicuous Enough

"A Question Of Ever-Increasing Ubiquity In Today's E-Commerce World."         The question: did an internet user’s online activities bind her to certain terms and conditions?          The majority opinion in Katherine Chabolla v. ClassPass Inc., et al, 23:15999 (9th Cir.  2/27/25) (Mendoza, Fitzgerald; Bybee, dsst.) affirmed the district court’s decision to deny ClassPass’s motion to […]

Discovery: Sixth District Holds Arbitration Agreement Is Enforceable Where Discovery Rules Are Lenient Enough

The Court Of Appeal Distinguished Between The More Lenient Discovery Provisions In Vo And The Tougher Discovery Restrictions In Aixtron.         In Vo v. Technology Credit Union, H051619 (6th Dist.  2/4/25) (Greenwood, Grover, Danner), the California Court of Appeal reviewed an arbitration agreement signed by Thomas Vo, an employee of Technology Credit Union (TCU). After […]

Unconscionability: Fourth District Div. 3 Finds Arbitration Provision Presented In English To Spanish Speaking Legal Client Was Not Enforceable

February 10, 2025 · Arbitration: Unconscionability

Presenting An English Contract To A Spanish Speaking Legal Client Illiterate In English Was Problematic         Justo Malo Sanchez filed a legal malpractice lawsuit against Consumer Defense Legal Group and its representatives, alleging issues with the firm's handling of his case. The retainer agreement he signed contained an arbitration clause, but Sanchez argued that the […]

Preemption, Choice Of Law: Effort To Compel Arbitration With CAL Choice Of Law Provision Is Preempted

Can An Employer Avoid The Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 With A California Choice Of Law Provision?         No. The EFAA preempts California law, rendering the arbitration agreement unenforceable in cases of sexual harassment disputes. That's the holding of  Casey v. Sup. Ct.,  D.R. Horton, Inc., et al […]

Deadlines, FAA: First Dist. Div. 1 Sides With Courts Holding FAA Does Not Preempt Prompt Payment Of Arbitrator CA Statute

The Court Distinguishes The Case From Hernandez v. Sohnen Enterprises, Inc.         Jenny-Ashley Colon-Perez sued her former employer, Security Industry Specialists, Inc. (SIS), for various employment-related claims. After agreeing to arbitrate, SIS failed to pay arbitration fees within the 30-day deadline required by California Code of Civil Procedure section 1281.98. Colon-Perez chose to withdraw from […]

Reviews: Who Owns This Sentence? — Book Reviewed By Your Blogger Marc Alexander

January 20, 2025 · Reviews

A History Of Copyrights And Wrongs.         David Bellos, an academic, translator, and biographer, and Alexandre Montagu, an IP attorney and founder of MontaguLaw, have written an engaging history of copyright law. Blogger Marc Alexander has written a review of the book. The review is republished here with the permission of the Journal of the […]

Agency: Third District Agrees Durable Power Of Attorney At Issue Did Not Confer Authority To Agent To Agree To Arbitrate

Authority To Make Medical Decisions Is Not The Same As Authority To Consent To Arbitration.         In Lombardo v. Gramercy Court, C098857 ( 3rd Dist. 12/31/24) (Robie, Earl, Mauro) the plaintiffs, Lisa Lombardo and others, sued Gramercy Court for wrongful death, negligence, elder abuse, and gross negligence after Elizabeth Stein, their relative, died following inadequate […]