Author: calmediation

PAGA: Employer’s Effort To Compel Employee To First Arbitrate Whether She Was An “Aggrieved Party” Under PAGA Fails

December 8, 2016 · Arbitration: PAGA

Hernandez v. Ross Stores Lines Up With Other California Cases Refusing To Split PAGA Claims Into Arbitrable And Non-Arbitrable Parts.      In Hernandez v. Ross Stores, Inc., No. E064026 (4/2 12/7/16) (Miller, Hollenhorst, Slough) (unpublished), the Court of Appeal upholds the trial court’s denial of an employer’s motion to compel arbitration of whether an employee […]

Settlement Agreements: Written Agreement To Dismiss Case And Enforce Settlement Agreement Is Enforceable, Though Agreement Was Not Filed With The Court

December 8, 2016 · Settlement Agreements

Court Describes Appeal As “A Tempest In A Teapot.”      Teapot with cherry or plum blossoms.  Between 1750 and 1850.  Library of Congress.      California has a convenient procedure for enforcing settlement agreements:  Code of Civil Procedure, section 664.6.  This allows a court to retain jurisdiction of a dismissed case for the purpose of enforcing […]

News: Wells Fargo Makes Effective Use Of Arbitration

December 6, 2016 · News

NYT Article Describes Bank’s Use Of Arbitration With Customers Complaining About Creation Of Sham Accounts.      Above:  Wells, Fargo & Co.'s Express Office, C Street, Virginia City.  1866.  Library of Congress.      The NYT, which ran a series of articles in 2015 critical about the spread of arbitration, has published an article dated December […]

Mediation/Condition Precedent: International Lawyers Also Worry About Consequence Of Skipping Mandatory Pre-Arbitral Step

It’s Not Exactly The Same As Skipping Mediation In A Home Sale Purchase In California . . . .      California courts have established that the consequence of not requesting mediation before suing for breach of a California Association of Realtor’s residential purchase agreement is that the plaintiff will not recover attorney’s fees even if […]

Arbitration, Public Policy, Record: Slight Record And Failure To Show Violation Of Well-Settled Public Policy Dooms Challenge To Arbitrator’s Award

Absence Of A Record Was A Major Problem For Appellant.      Law Offices of Mark Waecker, APC v. Pius Kim, B268212 (2/5 12/1/16) (Turner, Kriegler, Kumar) (unpublished) illustrates the proposition that an arbitrator’s decision is generally not reviewable for factual or legal errors.  Moncharsh v. Heily & Blase, 3 Cal.4th 1 (1992).  Therefore, the Court […]

Construction/Existence Of Agreement: CCA 4/1 Affirms Order Denying Motion To Compel Arbitration Because There Was No Agreement

Acknowledgment Of Employee Handbook Is Not Necessarily Agreement To All Its Contents.      Courts apply the rule requiring resolution of ambiguities against the drafting party “with peculiar force in the case of a contract of adhesion.”   That’s what happened in Rollins v. Stack & Associates, CPAs, No. D069390 (4/1 11/30/16) (Nares, Benke, Huffman) (unpublished), in […]

Automobiles, Consumers: Buyer’s Arbitration Award Exceeded $100K, And Auto Dealer Gets A “Do-Over” If Not Exactly An Appeal

Dealer Wanted To Go To Three-Arbitrator Panel After Receiving Adverse Arbitration Award, And Everyone Agreed That ADR Arbitral Forum Lacked “Appellate” Rules.  So?       Plenty of arbitration disputes arise from arbitration clauses in auto sales contracts and leases – hence our sidebar category, “Automobiles.”.  Here’s an unusual one, based on fairly common arbitration provisions.  Condon […]

PAGA: Agreement To Arbitrate “Aggrieved Person Status” Under PAGA Does Not Enable Employer To Enforce Arbitration Of Any Portion Of Representative Claim

November 30, 2016 · Arbitration: PAGA

Employer Sought To Distinguish Its Case Based On Specific Language Of Arbitration Clause . . . No Go.      Williams v. Superior Court, 237 Cal.App.4th 642 (2015) recognizes that a representative action waiver of a PAGA claim is ineffective because the PAGA claim is not divisible into separate individual and representative claims.  Because a representative […]

Conflicts: Disqualification Of Conflicted Attorney Does Not Extend To Law Firm Whose Retention Attorney Facilitates And To Whom Attorney Transfers Files

November 29, 2016 · Conflicts

Mediation Of Dispute Between Brothers Drew Our Attention To This Case.      Jogani v. Jogani, B268162 (2/1 11/25/16, mod. 11/28/16) (Chaney, Rothschild, Johnson) (unpublished) is about attorney disqualification and conflicts.  The underlying dispute among the Jogani brothers appears to have been sliding up and down the California courts for fifteen years, involving a number of […]

Settlement Agreements: California Court Won’t Interfere With Texas Judge’s Ruling Allowing Discovery Of Information Subject To Confidentiality Provisions In California Settlement

November 29, 2016 · Settlement Agreements

There Is No Absolute Bar To Discovery Of Information Designated Confidential In A Settlement Agreement.      In 2007, Younan Properties entered into a settlement agreement with its CFO Thompson requiring confidentiality.  Thompson had claimed that Younan Properties had engaged in unfair business practices, and wrongfully discharged him.  In 2014, investors sued Younan Properties for fraud […]