Author: calmediation

CCP 664.6 AND FRCP 41(a): Retention Of Jurisdiction To Enforce Settlement Agreement In Federal And California State Courts

Because Federal Courts Are Courts Of Limited Jurisdiction, The Procedures Differ.         We posted on December 4, 2017, about Sayta v. Chu, A148823 (1/5 11/29/17) (published), an opinion that "offers an object lesson on the requirements to invoke [Cal. Code of Civ. Proc.] section 664.6 and the consequences of failure to comply with those […]

Deadlines: Appellant Forfeited Ability To Challenge Judgment Confirming Arbitration Award Based On Lack Of Jurisdiction By Permitting The Arbitration To Proceed Without Objection

How Long You Can Wait To Challenge A Judgment Confirming Arbitration Award Depends On Whether Court Compelled Participation In The Arbitration, Or Whether You Simply Allowed The Arbitration To Proceed Without Objection.          Appellant waited more than seven years to attack a superior court judgment confirming an arbitration award in FIA Card Services, N.A. […]

Vacatur: First District, Div. 1, Refuses To Vacate Award For Alleged Lack Of Opportunity To Present Evidence, Ambiguity, Or Lack Of Jurisdiction

A Textbook Example Of How Difficult It Is To Challenge An Arbitration Award.         Our next case involved a family dispute in the California wine industry, following the death of the family patriarch.  Nickel v. Far Niente Wine Estates, LLC, et al., A150513 (1/1  12/29/17) (unpublished).          Affirming the trial court's denial of […]

Arbitration, Federal Arbitration Act, Public Policy: 9th Circuit Holds That FAA Does Not Apply To Agreements Between Prosecutors And Citizens Resolving Alleged Criminal Violations

And Such An Agreement  To Arbitrate Disputes Invoking The Criminal Law Would Be Contrary To Public Policy.         The context for our next case is California's Bad Check Diversion Program (Program), created to relieve California courts of the case overload caused by the criminalization of the writing of bad checks with intent to defraud.  The statutory […]

Reviews: Ari Berman’s “Give Us The Ballot”

December 25, 2017 · Reviews

Your Blogger Has Authored A Review Of Ari Berman's Book About The Voting Rights Act Of 1965.         I've written a review of Ari Berman's book, "Give Us The Ballot."  The review, which appears in the latest  issue of California Litigation, The Journal of the California State Bar, is republished here, with the permission […]

Arbitration, Discovery, FAA: Ninth Circuit Holds FAA Does Not Grant Arbitrators Power To Order Third Parties To Produce Documents Prior To An Arbitration Hearing

Ninth Circuit Joins Majority Of Circuits On Issue That Divides The Circuits.         Based on a reading of the "plain meaning" of the Federal Arbitration Act, specifically, 9 U.S.C. section 7, the Ninth Circuit holds:  "[T]he FAA does not grant arbitrators the power to order third parties to produce documents prior to an arbitration hearing."CVS […]

Arbitration, PAGA, Appealability: Fourth District, Div. 1 Holds That Trial Court Erred By Bifurcating Underpaid Wages Portion Of PAGA Claim And Ordering Arbitration Of That Part Of Claim

Civil Penalties Or Victim Specific Statutory Damages?          Lawson v. ZB, N.A. et al., and ZB, N.A., et al. v. Superior Court of San Diego, D071279 & D071376 (4/1  12/19/17) (Benke, Huffman, Haller), is the latest skirmish in the ongoing battle waged between employers and employees over whether Private Attorney General Act of 2004 […]

Arbitration, Gateway Issues, Delegation: USCA 4th Circuit Holds That Incorporation Of JAMS Rules Delegates Questions Of Arbitrability To Arbitrator

December 21, 2017 · Uncategorized

But There Is A Dissent . . .          Simply Wireless Inc. v. Mobile US Inc ., Nos. 16-1123, 16-1166 (4th Cir.  12/13/17) resulted in an interesting majority opinion authored by Judge Wynn, with Judge Harris, joining, and a dissent by Judge Floyd.  As a result, I have strayed beyond my usual beat of covering […]

Mediation/Condition Precedent: Fourth District, Division Three, Limits Mediation As A Condition Precedent In A CAR Contract For Fee Recovery

December 19, 2017 · Mediation: Condition Precedent

The General Rule In A California Association Of Realtors Purchase And Sale Agreement Requires Participation In Mediation As A Condition For A Prevailing Party To Recover Fees.         The general rule under the standard CAR purchase and sale agreement requires participating in mediation as a condition precedent for fee recovery.  The rule was explained by Justice […]