Category: Arbitration: Collateral Estoppel/Res Judicata

Arbitration: Issue Decided In Arbitration May Preclude Federal Claim In Case Where Employee Is Protected From Arbitration

Sarbanes-Oxley Federal Whistleblower Claim Is Precluded By Issues Decided In Arbitration, Though Employees Are Protected Against Mandatory Arbitration Of Whistleblower Claims.         Section 806 of the Sarbanes-Oxley Act (SOX) provides whistleblower protections, including protection against mandatory arbitration. Can issues decided against a former Tesla employee in arbitration preclude the employee's relitigation of issues in a […]

PAGA, Issue Preclusion: Employee Losing Labor Code Claims In Arbitration Ceases To Be Aggrieved Person With Standing To Sue For PAGA Claims

This Case Makes It Easier For Employers To Beat Back PAGA Lawsuits When Employee Loses Labor Code Claims In Arbitration — The Legal Tool Is Issue Preclusion.         In Julian Rodriguez v. Lawrence Equipment, Inc., B325261 (2/3  pub. 11/8/24) (Bershon, Edmon, Egerton), the plaintiff, Julian Rodriguez, alleged wage-and-hour violations under California’s Labor Code and pursued […]

PAGA, Issue Preclusion: Arbitrator’s Ruling In Favor Of Corporation Did Not Preclude Employees From Suing Manager For Wage And PAGA Claims

Trial Court's Denial Of Right To Amend Was Error.         The Rocha brothers, Thomas and Jimmy, sued their former employer U-Haul Co. of California, and their manager Sandusky, alleging Sandusky had harassed them at work. The matter was arbitrated and the brothers lost their claim against U-Haul. However, before the matter went to arbitration, the […]

Waiver: Fourth District Div. 2 Holds Lengthy Delay And Failure To Timely Take Affirmative Steps To Arbitrate Results In Waiver Of Right To Arbitrate

Thirty-Nine Page Slip Opinion Hinges On Issue Of Waiver.         The Court of Appeal addresses a variety of issues in the context of a complicated procedural history in Desert Regional Medical Center v. Leah Miller and Desert Regional Medical Center v. Lynn Fontana, E076058 and E076069 (4/2  1/6/23) (Codrington, Ramirez, Raphael).          The procedural history […]

Unconscionability, Severance, PAGA, Claim Preclusion: Second District Div 7 Holds Arbitration Agreement, Permeated With Substantive Unconscionability, Is Unenforceable

Trial Judge No. 1 Found The Arbitration Agreement Enforceable, No. 2 Found It Enforceable, And Court Of Appeal Agreed With No. 2.         Chris Mills sued his former employer for disability discrimination and related employment claims. Employer FSG successfully enforced an arbitration agreement, the trial judge holding unconscionable provisions in the agreement were severable. An […]

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 […]

Arbitration: Tetrad Of Unpublished Cases Present Issues Concerning Mandatory Fee Arbitration, Res Judicata, Existence Of Agreement, 1281.2, Appealability

Ferguson v. Camarillo Health Care District, B281856 (2/6  11/28/18) (Tangeman, Gilbert, Yegan) (unpublished).     When a an opinion begins, "Calling it an 'unproductive waste of time,' attorney Ralph T. Ferguson did not participate in mandatory arbitration of a fee dispute with his client Camarillo Health Care District (CHCD). The arbitrators ruled in favor of […]

Arbitration, FAA, Adequacy of Record, Collateral Estoppel, Fees: Five Unpublished Cases Involving Hodgepodge Of Issues Result In Four Affirmances And One Dismissal.

Arbitration Cases Fly Under The Radar.     In recent years, I have concentrated more on published arbitration cases than on unpublished cases — first, because the unpublished cases are not citable in California state courts, and second, because there are simply so many of them. However, today, I have gathered five unpublished cases appearing […]

Arbitration/Vacatur/Res Judicata: Ignoring Res Judicata Effect Of A Prior Arbitration Is At Most An Error Of Law, And Therefore Not In Excess Of The Arbitrator’s Power

Same Was The Case If The Arbitrator Awarded Nonrecoverable Costs.             Without saying the arbitrator made a mistake, the Court of Appeal explains in Dyna, LLC v. GreatCall, Inc., D071003 (4/1  10/10/17) (McConnell, Haller, O'Rourke) (unpublished), "even if the arbitrator erred by ignoring the res judicata effect of a prior arbitration award or […]

Arbitration, Res Judicata: Third District Holds That Licensee Not Participating In Arbitration Can Assert Res Judicata Effect Of Arbitration Award

Key Here To Finding Res Judicata (Claim Preclusion) Is Licensee's Derivative Liability.   Gold Dredge.  Klondike River.  May 31, 1915.  Library of Congress.          A confirmed arbitration award (which, however, was not reduced to judgment 1) enabled George Reed, Inc. to assert res judicata against Cal Sierra Development, Inc.  Cal Sierra Development, Inc., Plaintiff and […]