Author: calmediation

Arbitration/Stay/FAA: Ninth Circuit Adopts Rebuttable Presumption That An Order Compelling Arbitration But Not Explicitly Dismissing Underlying Claims Stays Those Claims

Finality Of Order Compelling Arbitration Depends On Context, “But Our Review Of That Context Is Weighted Against Finality”, Says Ninth Circuit Panel      The Federal Arbitration Act permits immediate appeal of “a final decision with respect to an arbitration,” 9 U.S.C. section 16(a)(3), which is a decision that “ends the litigation on the merits and […]

Review: Significant ADR Cases In 2013

January 26, 2014 · Reviews

Sixteen Cases – And We Posted About Twelve Of Them . . . Plus One More Supreme Court Case . . .      On January 10, 2014, I attended a meeting of the Orange County Bar Association Litigation Section.  The law firm of Connor, Fletcher & Hedenkamp LLP made a presentation on new statutes, new […]

Recommended Reading: Dr. Donna Shestowsky’s Article, “The Psychology of Procedural Preference: How Litigants Evaluate Legal Procedures Ex Ante”

January 19, 2014 · Reviews

At The Beginning Of Their Case, Litigants Prefer Mediation To Most Adjudicative Procedures       Dr. Donna Shestowsky, a Professor of Law at UC Davis, with a doctorate in psychology, has authored a very interesting study on litigants’ preferences, at the beginning of their case, for different dispute resolution procedures.  Her article, “The Psychology of Procedural […]

Mediation/Confidentiality/Settlement Agreement: Second District, Division 6 Affirms Judgment Enforcing Mediation Settlement Agreement – Statements Made During Mediation Are Inadmissible

Evidence Code Section 1119 Makes Anything Said During Mediation Inadmissible And Undiscoverable      We have posted from time to time on mediation and confidentiality, noting how difficult it is to set aside a settlement agreement based on statements made during the mediation process:  statements made during mediation, even to one’s own attorneys, are inadmissible.  Cassel […]

Arbitration/Disclosures: Fifth District Rules That Plaintiff/Appellant Forfeited His Objections To The Arbitrator’s Initial Disclosure Statement

Once Plaintiff Knew of Arbitrator’s Relationship With Defendant, Plaintiff Was On Inquiry Notice To Ask About Details      An arbitrator must make certain disclosures within 10 days of receiving notice of his or her nomination to serve as a neutral arbitrator.  See CCP section 1281.9.  Once the arbitrator makes those disclosures, a party has 15 […]

Arbitration/Settlement/CCP 664.6: Fourth District, Division 2 Affirms Judgments, Finding Settlement Agreement Is Not Too Uncertain To Enforce

December 26, 2013 · Arbitration: Section 664.6

A Roadmap For Drafting An Enforceable Settlement Agreement      In our next case, the factors supporting enforceability of a settlement agreement provide a roadmap for drafting an enforceable agreement.      Defendants appealed two identical judgments entered in related lawsuits, arguing that the trial court should have not enforced a settlement agreement because, among other things, […]

Mediation/Confidentiality: Court Of Appeal Upholds Denial Of JNOV Because Motion To Overturn JNOV Relied Heavily On Inadmissible Evidence Subject To Mediation Privilege

December 25, 2013 · Mediation: Confidentiality

Parties’ Agreement To Extend Mediation Beyond Ten-Day Period Following Communication With Mediator Made Evidence Inadmissible      Boy, does this case, involving a dispute between client (Porter) and attorneys (Wyner) have a history.  After the California Supreme Court ruled in Simmons v. Ghaderi, 44 Cal.4th 570 (2008) that waivers of mediation confidentiality by either implication or […]

Arbitration/Appealability/Vacatur/FAA/Class Action: Ninth Circuit Holds Non-Appealability Clause Relating To Arbitration Award Allocating Fees Among Class Counsel Attorneys Runs Afoul Of the Federal Arbitration Act

At Stake:  Allocation of $28M in Attorney’s Fees Among Plaintiffs’ Attorneys in Wal-Mart Wage and Hour Litigation      The scenario:  Plaintiffs’ class counsel prosecute wage and hour class action against Wal-Mart, plaintiffs’ counsel quarrel concerning proper allocation of $28M fee award, and the fee dispute is submitted to “binding, non-appealable arbitration” before an eminent arbitrator, […]

Waiver: Second District, Division 5 Holds Trial Court, Not Arbitrator, Should Decide Merits Of Waiver Of Arbitration By Litigation Conduct

December 18, 2013 · Arbitration: Waiver

Judicial Expertise And Judicial Economy Weigh In Favor Of Letting The Trial Court Make The Call On This Waiver Issue      In a 3-0 opinion penned by Presiding Justice Turner, the Court of Appeal holds, “[t]he trial court correctly ruled it, rather than an arbitrator, should decide the merits of the waiver by litigation conduct […]