Category: Arbitration: Choice of Law

Preemption, Choice Of Law: Effort To Compel Arbitration With CAL Choice Of Law Provision Is Preempted

Can An Employer Avoid The Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 With A California Choice Of Law Provision?         No. The EFAA preempts California law, rendering the arbitration agreement unenforceable in cases of sexual harassment disputes. That's the holding of  Casey v. Sup. Ct.,  D.R. Horton, Inc., et al […]

First District, Div. 1 Affirms Order Denying Petition To Compel Arbitration Because Defendant Failed To Establish Existence Of Arbitration Agreement

No Evidence Of Signed Agreement.         Bruno Fleming sued Oliphant Financial for allegedly violating the California Rosenthal Fair Debt Collection Practices Act. Oliphant unsuccessfully petitioned the trial court to compel arbitration. The Court of Appeal affirmed the trial court's order denying Oliphant's petition to compel arbitration. Fleming v. Oliphant Financial, LLC, A165837 (1/1  1/31/23) (Devine, […]

Arbitration, Agency, Choice Of Law, Discovery: 9th Circuit Holds District Court Should Allow Discovery To Determine If Client Authorized Attorney To Agree To Arbitrate

Factual Questions Existed As To Whether Lawyer's Client Authorized Agreement To Arbitrate.         Plaintiff Barbara Knapke sued PeopleConnect, the owner of Classmates.com, for allegedly making unauthorized use of her name and likeness. Before filing the lawsuit, Knapke's attorney Reilly logged in to the Classmates.com website, and in doing so, agreed to arbitrate. Did […]

Arbitration, Internet Commerce: Ninth Circuit Agrees Website Did Not Provide Sufficient Notice Of Agreement To Arbitrate

Clickwrap? Browserwrap? Scrollwrap? Sign-in Wrap?         When does one's use of a website result in an agreement to arbitrate? Concurring with the majority, Judge M. Miller Baker candidly observes that this is an "evolving and fact-bound area." Here, Judge Paul J. Watford, writing for the majority, and Judge Baker, concurring, agreed that the […]

Arbitration, Delegation, Choice Of Law: Sixth District Affirms Denial Of Motion To Compel Arbitration Because There Was No Agreement To Arbitrate

Whether An Arbitration Agreement Exists Was A Gateway Issue For The Court To Decide.         Agreeing with the trial court that there was no agreement express or implied to arbitrate, the Court of Appeal affirms the trial court's order denying employer's motion to compel arbitration in a putative class action wage and hours case brought […]

Arbitration, Employment, Choice Of Law, FAA: Second Dist., Div. 7 Holds Choice Of California Law Incorporates Substantive Law But Not Procedural Limitations On Arbitration In Contract Governed By FAA

Parties Could Have Specifically Incorporated Arbitration Limitations In California Labor Code Instead Of Generally Choosing California Law — In Theory.         California Labor Code §229 provides, in part, that actions to collect due and unpaid wages may be maintained without regard to the existence of any private agreement to arbitrate. And parties to an employment […]

Arbitration, Nonsignatories, Equitable Estoppel, International, Choice Of Law: 9th Cir. Affirms District Court’s Order Denying Motion To Compel Arbitration Pursuant To NY Convention

And Judge Bea Dissents.         In Setty v. Shrinivas Sugandhalaya LLP, No. 18-35573 (9th Cir. 7/7/21) (Nelson, Rawlinson; Bea, dsst.), the court holds that the district court did not  abuse its discretion by rejecting defendant SS Mumbai's argument that  plaintiff SS Bangalore should be equitably estopped from avoiding arbitration. Defendant SS Mumbai was a non-signatory […]

Arbitration, Choice Of Law, Nonsignatories: Foreign Nonsignatory To Partnership Deed Could Not Invoke Equitable Estoppel To Compel Arbitration

The Partnership Deed With The Arbitration Clause Was Entered Into In India, But The Court Applied US Federal Substantive Law To The Equitable Estoppel Issue. Incense for sale in Bangalore. Author: Meanest Indian. Creative Commons License.         Appellant/Defendant Shrinivas Sugandhalaya LLP (SS Mumbai), in a lawsuit with Appellees/Plaintiffs (SS Bangalore), sought to enforce an arbitration […]

Arbitration, Policy, Choice of Law, FAA, Severance: McGill v Citibank Lives: Arbitration Provision Eliminating Any Forum For Public Injunctive Relief Is Unenforceable

Case Offers Primer On McGill v. Citibank, N.A.         Defendant and appellant DACM, Inc. (Del Amo) sold a motorcycle to Joseph Mejia, who paid some cash and financed the remainder of the purchase with a credit card. And, the credit card included an arbitration provision covering Del Amo. So when Mejia sued Del Amo for […]

Arbitration, Choice Of Law, Claim Preclusion: 9th Circuit Rules That In Diversity Case, State Law Governs Claim Preclusion As Applied To Confirmed Arbitration Award

An Issue Of First Impression.     In NTCH-WA, Inc. v. ZTE Corporation, Inc. v. ZTE Corporation, No. 17-35833 (9th Cir.   4/25/19) (Gould, Paez, Pregerson), the Court of Appeals held that an arbitration award and its confirmation by a district court in Florida, barred plaintiff NTCH-WA from pursuing claims against ZTE Corp. under the doctrine of […]