Category: Arbitration: Delegation

Arbitration, Class, Gateway Issues, Employment: A Rift In Court Of Appeals Decisions As To Whether Judge Or Arbitrator Decides If Agreement Allows Class-Wide Arbitration

Fourth District Says When Agreement Is Silent, Judge Decides; Second District Says Arbitrator Decides – So The California Supreme Court Will Have To Decide.      GATEWAY.  Carol M. Highsmith, photographer.  2013.  Library of Congress.      When the arbitration agreement is silent, who gets to decide whether the arbitration agreement allows for class arbitration?  Judge or […]

Gateway Issues: A Primer On Arbitrability

Richard Chernick, Esq. of JAMS Has Written “A Primer On Arbitrability”.      I have posted frequently about “gateway” arbitrability issues, including recent developments concerning gateway arbitrability issues in class and representative actions, and distinctions between substantive and procedural gateway arbitrability issues.  See my posts of November 17, 2014, and October 13, 2014.  In fact, “Gateway […]

Arbitration/Gateway Issues: Judge, Not Arbitrator, Gets To Decide Whether Agreement To Arbitrate Authorizes Class Arbitration When Contract Is Silent – And That Goes For Representative Arbitration Too

PAGA Is A Representative, Not A Class Action, And So Judge Gets To Decide Whether PAGA Action Is Subject To Arbitration.      Defendant and employer Garden Fresh Restaurant Corporation petitioned for a writ of mandate seeking a writ directing the trial court to vacate part of an order leaving it to the arbitrator to determine […]

Court Of Appeal Affirms Order Denying Employee’s Petition To Compel Arbitration And Lays Out Framework For Determining Who Decides Class Arbitration Question And Whether Class Arbitration Is Appropriate

  Fourth District, Division Three Disagrees With U.S. Supreme Court Decision That Found Class Arbitration Question Is A Procedural Issue For Arbitrators To Decide      Affirming a trial court’s order denying an employee’s petition to compel class arbitration of his wage and hour claims, the Court of Appeal in Network Capital Funding Corporation v. Papke, […]

Arbitration/Delegation: Trial Court Lacked Authority To Rule On Enforceability Of Arbitration Agreement, Because Authority To Do So Was Delegated To Arbitrator (Even Though Delegation Clause Was Procedurally Unconscionable)

May 16, 2014 · Arbitration: Delegation

Split Of Opinion In District Two Over Enforceability Of Delegation Clauses Poker game of construction workers at canteen, Shasta Dam.  Russell Lee, photographer.  1939.  Library of Congress.          When Lourdes Tiri, a cook fired by Lucky Chances, a card-club casino and restaurant, sued her employer, the employer petitioned to compel arbitration.  However, the trial court […]

Arbitration/Deadline/Delegation/Vacatur: Fourth District, Div. 1 Affirms Trial Court’s Order Denying Plaintiffs’ Motion To Vacate Award Because Parties Agreed Arbitrators Could Decide Whether The Arbitration Was Timely — Or Not

Arbitrators Acted Within Their Powers, So It Didn’t Change Results Even If They Erred      In the underlying dispute, Plaintiffs obtained a substantial award of $150,000 compensatory and $302,784 in punitive damages, blown out when the Court of Appeal ruled that the dispute, related to lease provisions, was subject to arbitration.  Defendants then moved, successfully, […]

Arbitration/Nonsignatories: In Case Of First Impression, First District, Div. 5 Holds That An Arbitration Clause In Trust Document Does Not Bind Trust Beneficiary

Court Would Not Compel Arbitration Here Where The Beneficiary Had Not Sought The Benefits Of The Trust Instrument, But Rather Challenged Its Validity       Pamela McArthur v. Kristi McArthur, A137133 (1st Dist. Div. 5 March 11, 2014) (Bruiniers, Jones, Needham) is a case arising out of an inharmonious “sister act.”      The scenario is not […]

Arbitration/Delegation/Enforceability: SCOTUS Rules Federal Appeals Court Should Not Have Thrown Out $185M Award That BG Group Won Against Argentina

Majority Opinion Distinguishes Between Who Decides Arbitrability Of Claims And Who Decides Claims-Processing Requirements     On February 26, 2014, I posted that it was time to watch for a decision in BG Group, PLC v. Republic of Argentina,__ S.Ct. __ , 2014 WL 838424.  The case was decided on March 5, 2014.      Following an […]

Arbitration/Delegation: Ninth Circuit Holds Incorporation Of UNCITRAL Arbitration Rules Delegates Questions Of Arbitrability To The Arbitrator

July 28, 2013 · Arbitration: Delegation

 Ninth Circuit, In A Case Of First Impression, Follows Second And D.C. Circuits      In a case of first impression for the Ninth Circuit, the Court of Appeals holds “that as long as an arbitration agreement is between sophisticated parties to commercial contracts, those parties shall be expected to understand that incorporation of the UNCITRAL […]

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 […]