Author: calmediation

Federal Arbitration Act/Pending Cases: SCOTUS Hears Argument In Kindred Nursing Centers Limited Partnership v. Clark

Argument Is Summarized In SCOTUSblog.     On February 23, 2017, Professor Ronald Mann of Columbia Law School provided argument analysis in SCOTUSblog of yesterday's oral argument in Kindred Nursing Centers Limited Partnership v. Clark.   By the tenor of the argument, which appears to have been hostile to Kentucky's position that the right to try personal injury […]

Arbitrability: Court, Rather Than Arbitrator, Gets To Decide Whether There Was Fraud In The Inducement To Enter Into Arbitration

February 23, 2017 · Arbitration: Gateway Issues

The Important Distinction Is Whether Fraud In The Inducement Applies To The Contract Or To The Arbitration Clause.     Though unpublished, Milder v. Holley, B267974 (2/5 1/31/17) (Kumar, Kriegler, Baker) has facts that neatly clarify an important gateway issue: does a judge or an arbitrator get to decide whether there was fraud in the inducement in […]

Arbitration, Automobiles, and Construction Of Agreement: Agreement Providing For Right Of Party To Request “A New Arbitration” Is Effective Even In Arbitration Forum That Does Not Provide Appeal Rules

February 23, 2017 · Uncategorized

The Arbitration Clause Analyzed By The Court Is Common In Automobile Sales Contracts.     The Arbitration Clause analyzed in Raczynski v. Daland Nissan, Inc., et al., A146992 (1/5 2/15/17) (Bruiniers, Jones, Needham) (unpublished), provides that the arbitrator’s award “shall be final and binding on all parties, except that in the event the arbitrator’s award for a […]

Collective Bargaining: Second District, Division 4, Holds Trial Court Properly Denied Motion To Compel Arbitration Because Collective Bargaining Agreements Did Not Include “Unmistakable Waiver Of The Right To A Judicial Forum For Individual Statutory C

Where Statutory Violations Are Alleged, Presumption Of Arbitrability Applying To Contractual Disputes Arising Out Of A Collective Bargaining Agreement Does Not Apply.     Collective bargaining agreements (CBAs) are a different animal requiring close scrutiny when the question of arbitrability arises in an employment dispute. In Vasserman v. Henry Mayo Newhall Memorial Hospital, No. B267975 (2/4 2/7/17) […]

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 […]