Author: calmediation

Unconscionability, PAGA, Severance: 9th Circuit Reverses District Court’s Order Denying Motion To Compel Arbitration

Panel Rejects Employee’s Arguments That Six Provisions Are Unconscionable, Requires Severance Of “Judicial Carve-Out” Provision, And Punts On “Reaffirmation Clause” Provision.     Poublon v. C.H. Robinson Company, et al., No. 15-55143 (9th Cir. 2/3/17) (Ikuta, Callahan, Bea) is an opinion that employers will likely cite when arguing against employee claims that an arbitration clause is substantively […]

Arbitration/Review: Fourth District, Division Two Affirms The Woody Allen Principle

Woody Allen Principle: "80% Of Life Is Showing Up." Northeast elevation – Woody Allen Road Bridge, Spanning Oothalooga Creek at County Road 316, Adairsville, Bartow County, Georgia. Library of Congress.        In Newman v. The Ramona Terrace Community, LLC, No. E066400 (4/2 2/3/17) (Codrington, Hollenhorst, Slough) (unpublished), the Court holds: "Because Newman agreed […]

PAGA, Severability: Second District, Division 4 Reposts Montano PAGA Opinion Upon Lifting Of Bankruptcy Stay

Two Years Later . . .     On January 7, 2015, we posted about Montano v. The Wet Seal Retail, Inc., B244107 (2nd Dist. Div. 4 1/13/15) (certified for pub.). This is a Private Attorneys General Act case following the holding in Iskanian v. CLS Transportation Los Angeles, LLC, 59 Cal.4th 348 (2014), that waiver of the […]

Collective Bargaining: Ninth Circuit Rules That Railway Labor Act Requires Flight Attendant To Resort To Arbitral Mechanism Required By Collective Bargaining Agreement Instead Of Washington State Labor Agency

This Is A Railway Labor Act Preemption Case.     Alaska Airlines v. Schurke, et al., No. 13-35574 (9th Cir. 1/25/17) is not about the merits of whether a flight attendant gets to use her vacation time to care for her sick child – a Washington state agency had ruled in her favor on the merits. Rather, […]

Enforcement Of Arbitration Agreement, Non-Signatories: Ninth Circuit Affirms Order Denying Samsung’s Motion To Compel Arbitration Of Class Complaint Filed By Purchaser Of Galaxy S4 Phone

Customer Agreement With Verizon And Samsung Product And Safety & Warranty Agreement In The Box Failed To Bind Plaintiff To Arbitrate.      In Norcia v. Samsung Telecommunications America, LLC, et al., No 14-16994 (9th Cir. 10/17/17) (Ikuta, Thomas, Bea), Judge Ikuta provides in depth analysis of whether a 101 page brochure containing an arbitration provision […]

Arbitration/Class Action Waivers: Supreme Court Has Granted Cert To Hear Cases Addressing Whether National Labor Relations Act Prohibits Class Action Waivers

Ninth Circuit Case of Morris v. Ernst and Young Is One Of The Three Cases.     On December 9, 2016, I linked my article on "The Politics of Arbitration" to this blog. In that article, I predicted, "Morris [v. Ernst and Young] could serve as a springboard for sending divergent opinions about the enforceability of arbitration […]

Arbitration/Appealability: Ninth Circuit Dismisses Appeal Of Order Denying Motion To Compel Arbitration Because Appellants Invoked California Arbitration Act Rather Than Federal Arbitration Act

January 17, 2017 · Arbitration: Appealability

A Trap For The Unwary . . .     Kum Tat Limited v. Linden Ox Pasture, LLC, No. 14-17472 (9th Cir. 1/13/17) (Hurwitz, Lucero, Graber) presents a trap for the unwary.     Plaintiff Kum Tat Limited sued in California state court in connection with its attempted purchase of residential property for approximately $40M, after its attempted purchase […]