Author: calmediation

Arbitration, Consumers, Delegation, Gateway Issues, Unconscionability: Fifth District Vacates Parts Of Trial Court Order About Unconscionability And Arbitrability, And Upholds Delegation Clause Sending Consumer Dispute To JAMS Arbitrator

Enforceable Delegation Provision Means The Buck Does Not Stop With Court, But Gets Passed To Arbitrator.         Aanderud v. Superior Court (Vivint Solar Developer, LLC, Real Party In Interest), F073277 (5th Dist.  7/26/17) (Gomes, Hill, Meehan), is worth reading for its analysis of how a delegation provision is applied to a consumer arbitration, where the […]

Choice Of Law, Employment, Unconscionability: Concluding That Arbitration Agreement Was Not Unconscionable Under Alabama Law, Third District Reverses Trial Court’s Order Denying Employer’s Petition To Compel Former Employees To Arbitrate

Arbitration Agreement Included Alabama Choice Of Law Provision. Alabama State Flag.         When former employees, who were hired as temporary claim adjusters, sued the insurance company that had hired them in a class action complaint alleging various employment violations, the California trial court agreed that the arbitration agreement was unconscionable.  Analyzing the trial court's order under […]

Arbitration, Delegation, Class Action: Fourth District, Div. 3 Holds Arbitrator Must Decide Class Action Question Based On Language Of The Arbitration Agreement

In California, There Is No Universal Rule That Arbitrator Or Court Decides Whether A Class Action Can Be Arbitrated — It Depends On The Agreement.         The United States Supreme Court has held that a party may not be compelled to submit to class arbitration unless there is an express contractual basis for  concluding the  […]

Mediation/Family Law:Pro Per Father Was Given Fair Opportunity To Oppose Mother’s Request For A Move-Away Order, Despite Feeling Ambushed By Mediator’s Decision To Discuss The Issue

July 20, 2017 · Mediation: Family Law

Under The Circumstances, The Mediator's Decision To Discuss The Mother's Move-Away Request Was "Understandable".         In family law, disputes are often resolved through mediation.  In Alkebulan v. Dunham, D069434 (4/1  7/20/17) (Benke, O'Rourke, Dato) (unpublished), father, who was unrepresented by counsel, felt blind-sided when mother raised the issue of a move-away order with their year-old […]

Arbitration, CCP 1281.2, FAA Preemption: Second District, Div. 8 Holds That Procedural Provisions In California Arbitration Act Are Not Preempted By The FAA, Allowing Court Proceedings To Go Forward, Without Having To Arbitrate

The Holding Fills A Gap In California Law.         Los Angeles Unified School District v. Safety National Casualty Corporation, B275597 (2/8  7/12/17) (Grimes, Bigelow, Sortino) addresses a problem that can bedevil litigators when a party seeks to use California Code of Civil Procedure section 1281.2 to thwart arbitration.  Section 1281.2 allows a court to deny a […]

International Arbitration, Gateway Issue, Delegation, Scope: Ninth Circuit Holds That Incorporation Of ICC Rules Delegates Issue Of Scope Of Arbitration To The Arbitrator

Ninth Circuit Joins Second And First Circuits.         In Portland General Electric Company v. Liberty Mutual Insurance Company, et al., No 16-35628 (9th Cir. 7/10/17) an opinion authored by Senior District Judge Jed S. Rakoff, the 9th Circuit joins the 2nd and 1st Circuits to conclude that "incorporation of the rules of the ICC [International […]

Conflicts: Court Of Appeal Affirms Order Denying Motion To Disqualify Counsel Who Allegedly Learned Confidential Information Through Settlement

June 30, 2017 · Conflicts

A Hypothetical Question:  What If Confidential Information That Could Be The Basis For Disqualifying An Attorney Is Obtained Through Mediation?         Gobar v. Gong, D070876 (4/1  6/26/17) (Huffman, Benke, Haller) (unpublished) involves unsuccessful efforts by defendant Gong to disqualify plaintiff Gobar's attorney who earlier represented a law firm  seeking to collect a money judgment from […]

Arbitration/Employment/Class Actions/Pending Cases: Office Of The Solicitor General Changes Its Position On NLRB v. Murpy Oil, USA

The Issue:  Do Employee Agreements To Waive Class Actions And Arbitrate Violate The Right Of Employees To Engage In Collective Action Under The National Labor Relations Act?         Amy Howe reports on June 19, 2017, in SCOTUSBlog, that the Office of the Solicitor General, after the change of administration, has done a volte-face in a […]