Author: calmediation

PAGA: Under Settled Principles Of Stare Decisis, Fourth District, Div. 2 Follows California Supreme Court Opinion In Iskanian, Not SCOTUS Opinion In Concepcion

January 27, 2015 · Arbitration: PAGA

Court Concludes Trial Court Correctly Denied Petition To Compel Employee To Arbitrate His PAGA Claims.      On January 20, 2014, we blogged that SCOTUS had denied petitioner’s writ of certiorari in the United States Supreme Court (petition for cert filed Sept. 22, 2014, No. 14-341).  That denial of cert is already having consequences, for in […]

Employment: After Rehearing, Court Of Appeal Again Reverses Trial Court’s Order Denying Employer’s Motion To Compel Arbitration

Same As Before – Only This Time A Third Judge Signs On To The Opinion      I blogged about this very same case in a post on August 27, 2014.  So I was puzzled at first as to why another published opinion was issued following rehearing on January 20, 2015.  Cruise v. Kroger Co., B248430 […]

PAGA: SCOTUS Punts On Iskanian, Denying Cert Petition

January 20, 2015 · Arbitration: PAGA, Pending Cases

 PAGA Issue Will Continue To Percolate Through Federal Courts.       The United States Supreme Court today denied the petition for a writ of certiorari brought by CLS Transportation Los Angeles, LLC, No. 14-341.  Left intact, for now, is the California Supreme Court’s holding in Iskanian v. CLS Transportation Los Angeles, LLC, 59 Cal.4th 348 (2014), […]

PAGA: Iskanian Compels Reversal Of Order Dismissing Plaintiff’s Representative Claims–And The PAGA Issue Is Presented In Cert Petition To The United States Supreme Court

January 15, 2015 · Uncategorized

Is A Class Action Waiver Different From A Representative Action Waiver?      On January 7, 2015, I posted that on September 22, 2014, a cert petition was filed in the SCOTUS to consider the PAGA/FAA preemption issue in Iskanian v. CLS Transportation Los Angeles, LLC, 59 Cal.4th 348 (2014).       This is how the issue […]

Arbitration, Class, Gateway Issues, Employment: A Rift In Court Of Appeals Decisions As To Whether Judge Or Arbitrator Decides If Agreement Allows Class-Wide Arbitration

Fourth District Says When Agreement Is Silent, Judge Decides; Second District Says Arbitrator Decides – So The California Supreme Court Will Have To Decide.      GATEWAY.  Carol M. Highsmith, photographer.  2013.  Library of Congress.      When the arbitration agreement is silent, who gets to decide whether the arbitration agreement allows for class arbitration?  Judge or […]

Arbitrator’s Refusing To Issue A Subpoena And Limiting Arbitration Hearing To One Day Did Not Provide Basis For Vacating Award.

Arbitrators Can Make Mistakes And Here The Record Didn’t Even Show A Mistake Had Been Made.        A major attorney’s fees dispute between a law firm and its client hinged on when mediation ended, for the parties agreed that the law firm would receive a five percent contingency fee for a successful mediation, and a […]

Vacating Arbitration Award: Plaintiff Waived Request For Continuance When Her Counsel Stipulated To Proceed With Arbitration Without Live Testimony

Failure To Postpone Arbitration Hearing Upon Sufficient Cause May Be Grounds For Vacating Award – But Not When Request For Continuance Is Waived !      Plaintiff sought to postpone an arbitration hearing in a wrongful death/medical malpractice action, because she was studying abroad, and counsel’s medical condition adversely affected his cognitive status and performance.  However, […]

Arbitration, Deadlines, Vacatur: Court of Appeal Rejects Carrier’s Argument That Arbitrator Exceeded Her Powers And That Award Was Untimely.

      Lanois v. Employers Fire Insurance Company, Case No. B251403 (2/1 Jan. 9, 2015) (Chaney, Rothschild, Johnson) (unpublished) involved an underinsured motorist insurance carrier’s challenge to an arbitration award, on the grounds that the award was rendered untimely, and that the arbitrator exceeded her powers by adding interest to a 950K award, after the […]

Automobiles: On Balance, Arbitration Provisions In Auto Sales Contract Are Found Not To Be Unconscionable

January 8, 2015 · Arbitration: Automobiles

Unconscionability Challenge To Identical Arbitration Provision In Industry-Drafted Automobile Sales Contract Is Still Pending In Sanchez Before California Supreme Court.       Our next case is a fine example of ad hoc justice, for the Court of Appeal concludes that “on balance”, the arbitration provisions in a standard automobile industry sales contract are not unconscionable.  A […]

Arbitration, Severability, PAGA: Second District, Div. 4 Affirms Order Denying Motion To Compel Arbitration Because PAGA Claims Could Not Be Arbitrated, And PAGA Claims Were Not Severable

Court of Appeal Recognizes It Is Bound By Iskanian, Until SCOTUS Resolves Validity Of PAGA Waivers.          Montano v. The Wet Seal Retail, Inc., B244107 (2/4 Jan. 7, 2015) (Epstein, Willhite, Manella) (published) is the latest case to follow the holding in Iskanian v. CLS Transportation Los Angeles, LLC, 59 Cal.4th 348 (2014), that waiver […]