Author: calmediation

Arbitration/Employment/Unconscionability/FAA: Employee’s Waiver Of Dispute Resolution Berman Hearing In Favor Of Arbitration, While Not Per Se Improper, Could Still Be Unconscionable

SCOTUS Ruling In Concepcion Causes California Supreme Court To Change Its Position On Waiver of Berman Hearing        So what is a Berman hearing?  It is a dispute resolution forum established by the Legislature to assist employees in recovering wages owed.  Labor Code section 98.  The procedure is named after legislator Howard Berman, who instituted […]

Arbitration/Agency/Enforceability/CCP 1281.2: Nursing Home’s Petition To Arbitrate Fails For Lack Of Evidence That Husband Delegated Authority To His Wife To Agree To Arbitration

  Spouses Are Not Automatically The Agents Of One Another When It Comes To Making Health Care Decisions      Mrs. Goldman signed an arbitration provision on behalf of her husband who entered a nursing home.  After Mr. Goldman died, Mrs. Goldman sued on behalf of her husband for elder abuse and related wrongs, and in […]

Arbitration/Employment: Arbitration Agreement Fails To Clearly And Unmistakably Refer Statutory Discrimination Claims To Arbitration

November 5, 2013 · Arbitration: Employment

Collective Bargaining Agreement Must Clearly and Unmistakably Refer Statutory Discrimination Claims to Arbitration in Order Make Arbitration Mandatory      Defendant Mid-Wilshire Health Care Center appealed from an order denying its motion to compel arbitration and to stay a wrongful termination action filed by plaintiff Mendez, a nurse assistant.  After determining the provisions of a collective […]

Arbitration/Employment/Public Policy: Private Attorney General Act Claims Need Not Be Arbitrated

PAGA Claims Are Outside the Principles of the FAA and the Supreme Court Decisions Applying It      The Private Attorney General Act of 2004 (PAGA), Labor Code sections 2698 through 2699.5, authorizes actions by aggrieved employees on their own behalf and on behalf of other employees to recover civil penalties from employers for Labor Code […]

Arbitrations/Automobiles: Fourth District, Division 2, Finds Form Purchase And Sale Agreement Used By Many New Car Dealers Not Unconscionable

November 2, 2013 · Arbitration: Automobiles

Appellate Opinion Is Divided And Issue Is Before The California Supreme Court Automobile wreck.  Between 1918 and 1920.  Library of Congress.      The Fourth District, Division 2, has added one more appellate opinion to the mix of opinions concerning whether a form purchase and sale contract used by many new car dealers in California and […]

Arbitration/Enforceability: Arbitration Agreement Is Valid Notwithstanding Absence Of Agreed Method For Appointing Arbitrator

November 2, 2013 · Arbitration: Enforceability

California Code of Civil Procedure Section 1281.6 to the Rescue      The failure of an arbitration agreement to provide a method for appointing an arbitrator need not be fatal.      Our next case arose from Plaintiffs’ efforts to recover allegedly unpaid progress payments under a construction contract for remodeling Defendants’ home.  Plaintiffs sued Defendants for […]

Arbitration/Employment/Class Action/Waiver: Fourth District, Division 2 Reverses Trial Court’s Denial Of Petition To Compel Arbitration Of Employee Claims

The Court Of Appeal Also Directs Entry Of Order Granting Employer’s Petition To compel Arbitration On An Individual Basis      Employee Arroyo’s complaint alleged his employer engaged in wage and hour practices that violated the California Labor Code.  The trial court denied the employer’s petition to compel arbitration, but this denial was reversed on appeal […]

Arbitration/Scope: Arbitration Provision In Operating Agreement Of LLC Investment Vehicle Does Not Govern Relationship Between Investors And Investment Advisor

November 1, 2013 · Arbitration: Scope

  Basis For The Wrongs Alleged By Plaintiffs Was A Separate Investment Services Agreement Containing No Arbitration Provision      Stephen Goldberg and Victoria Pynchon sued their investment advisors, Coggins Company, for breach of contract, professional negligence, and other claims relating to a real estate investment gone sour in Wildomar Investors, LLC. Among other things, Plaintiffs […]

Arbitration/Unconscionability/Employment: First District, Division 1 Concludes Arbitration Agreement Is Not Unconscionable And Reverses Trial Court’s Order Denying Arbitration

  Failure To Attach AAA Rules And Employer’s Unilateral Ability to Modify the Arbitration Agreement Were the Issues Here      Plaintiff Peng sued her employer for employment discrimination and related claims.  After the trial court denied defendant’s motion to compel arbitration, the employer appealed.  On appeal, the issues were whether the employer’s failure to attach […]

Arbitration/Vacatur: Second District, Division 7 Refuses To Vacate $26.8 Million Arbitration Award

 Quarrel With Arbitrator’s Reasoning And Conclusion Provides No Grounds For Reversing Trial Court’s Order Affirming Arbitration Award      Following a failed real estate investment, HCR Moorpark Investors, LLC obtained an order confirming a $26.8 million arbitration award in its favor.  With so much at stake, it is not surprising that defendants appealed, but the case […]