Category: Arbitration: Construction of Agreement

Construction Of Arbitration Agreement: Court Of Appeal Agrees Arbitration Clauses Were Unrelated To The Dispute For Which Respondents Seek Damages

Beware The Pleading Admission!      “ "Beware the Jabberwock, my son! The jaws that bite, the claws that catch!”      Plaintiffs/Respondents alleged Defendants/Appellants misrepresented they could raise sponsorship financing necessary for Plaintiffs to produce reality television shows, produced the show entitled “The Players Club” at considerable expense, and learned the financing was not forthcoming.  Plaintiffs […]

Arbitration/Employment/Enforceability/Unconscionability: 2nd District, Div. 1 Reverses Order Denying Motion To Compel Arbitration (Published), And 4th District, Div. 3 Affirms Order Denying Motion To Compel Arbitration (Unpublished) In Employment Cases

The Divergent Outcomes Are Explained By The Peculiar Facts (Of Course) 1.  Cruise v. Kroger Co., B248430 (2/3 Aug. 27, 2014) (Aldrich, Klein – third member of panel unavailable).      Employer Kroger Co., parent of Ralphs, which had loaded an arbitration policy with one-sided provisions favoring the employer, moved to compel arbitration of an employment […]

Employment/Construction of Arbitration Agreement: Fourth District, Div. 3 Certifies Rebolledo v. Tilly’s, Inc. For Publication

Court Agreed With Trial Court That Parties’ Arbitration Agreement Expressly Excluded Statutory Claims From The Arbitration Obligation.      On July 14, 2014, I blogged about Rebolledo v. Tilly’s, Inc., in which the Court of Appeal, 4th District, Division 3, affirmed the trial court’s order denying an employer’s motion to compel arbitration of an employee’s putative […]

Arbitration/Choice of Law/FAA/Employment/Unconscionability: Court of Appeal Concludes Plaintiff’s Wage Claims Are Encompassed By Parties’ Contractual Agreement, Reversing Trial Court’s Denial Of Petition To Compel Arbitration

  Also, Burdens Upon The Employee Were Not So Great As To Make Arbitration Provision Unconscionable      In our next case, the Court of Appeal, in a published opinion, reversed the trial court’s denial of a petition to compel arbitration.  Galen v. Redfin Corporation, A138642 (1st Dist. Div. 1 July 21, 2014) (Dondero, Margulies, Becton) […]

Arbitration/Construction Of Agreement/Jurisdiction: Parties’ Arbitration Agreement Expressly Excluded Statutory Wage Claims From Arbitration Because It Excluded Claims “Within The Jurisdiction” Of The California Labor Commission

Just A Matter Of Contract Interpretation      Judges must relax a little when they can say, as does Justice O’Leary, the author of the next opinion, “The sole issue presented in this appeal is simply a matter of contract interpretation.”  Rebolledo v. Tilly’s, Inc., G048625 (4th Dist. Div. 3 July 8, 2014) (O’Leary, Ikola, Thompson) […]

Arbitration/Standard of Review: Arbitrator Acted Within Power Under Arbitration Clause In Awarding Fees, But Sanctions Award Is Denied As Appeal Was Not Wholly Frivolous

Standard Of Review Pretty Much Ordained The Result Here, And Nothing Was Changed By Appealing      This is one of those “Cain v. Abel” disputes, in which beneficiaries/brothers (Douglas and Martin Buser), fought over their parents’ family trust.  It appears Douglas fought tooth and nail, but unsuccessfully, getting hit with attorney’s fees assessed against his […]

Arbitration/Employment/Construction of Agreement/Waiver: Second District, Div. 6, Affirms Trial Court’s Refusal To Preclude Employee With Statutory Grievance From Filing Judicial Action

Employee Here Did Not Clearly And Unmistakably Waive Right To A Judicial Forum      Certain distinctions are importantly at play in Volpei v. County of Ventura, Case No. B243954 (2nd Dist. Div. 6 Nov. 7, 2013) (Gilbert, P.J., author 3:0):  statutory versus contractual rights, mandatory versus voluntary arbitration, unilateral versus bilateral right to initiate arbitration, […]

Arbitration/Employment/Unconscionability: Qualifying Language Requiring Compliance With “Applicable Law” Saves Arbitration Agreement From Being Unconscionable

     Washington D.C. Bicycle Rental Shop. 1942.  Marjory Collins, photographer. Library of Congress.      Plaintiff Corbin sued her employer Specialized Bicycle Components, Inc. and its president for harassment, discrimination, and wrongful termination.  The trial judge, who commented about the defendant’s failure to provide the JAMS rules, found the agreement unconscionable, and refused to compel arbitration.  […]

Arbitration/Collective Bargaining/Construction of Agreement: In 4-3 Decision, California Supreme Court Rules That City of Los Angeles Must Arbitrate City’s Furlough Decisions

Dissenters Worries About Practical Consequences of Arbitrating Furlough Dispute In Budgetary Crisis      With this post, I inaugurate a new sidebar category:  Collective Bargaining.      Facing a fiscal emergency, the City of Los Angeles adopted a mandatory furlough program for its civilian employees.  Represented by a union, the employees filed grievances, arguing the furloughs violated […]

Arbitration/Fees/Construction of Agreement/Mediation/Settlement Agreement: Limiting Language in Settlement Agreement Required Arbitrator, Not Court, To Determine Fees

"Customary Provision Allowing for the Award of Legal Fees in Any Action on a Contract" Was Missing Here       This case presents a common issue: whether a prevailing party must seek fees from the arbitrator or from the trial court. Here, the issue was resolved by express, non-standard language in a settlement agreement. DeSena v. […]