Category: Arbitration: Employment

Arbitration/Employment/Waiver: Employer Did Not Waive Right To Enforce An Arbitration Agreement By Waiting Until Employee’s Wage Claim Had Been Heard In A Berman Hearing

  Employer Did Not Waive Its Right To Arbitrate Wage Claim And So Trial Court’s Order Denying Employer’s Motion To Compel Arbitration Is Reversed      Fremont Automobile Dealership, LLC, A137266 (1/2 July 23, 2014) (Richman, Kline, Brick) (unpublished) addresses the still somewhat murky relationship between the interaction of an arbitration agreement and the statutory right […]

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/Employment/Class/Waiver/FAA/Public Policy: California Supreme Court Rules in Iskanian: Yes On Waiver Of Class Action, No On Waiver Of PAGA Claims

  Iskanian Decision Yields Opinion Of Four, Plus Justice Chin, Concurring, Plus Justice Werdegar, Concurring And Dissenting      In a much-awaited decision, the California Supreme Court has ruled that a state’s refusal to enforce a class action waiver on grounds of public policy or unconscionability is preempted by the Federal Arbitration Act (FAA), but that […]

Arbitration/Waiver/Employment: Substantial Evidence Supported Finding That Employer Waived Right To Arbitrate

Substitution Of New Named Plaintiff To Represent Class Didn’t “Restart The Clock”.      In Jacoby v. Islands Restaurants, L.P., No. B250886 (2nd Dist. Div. 5 June 20, 2014) (Turner, Kriegler, Mink) (unpublished), the Court of Appeal ruled that substantial evidence supported the trial court’s finding that defendant employer had waived its right to arbitrate.       […]

Arbitration/Enforcement: Lack Of Written Arbitration Agreement Proves Fatal To Funeral Director/Embalmer’s Appeal Of Order Denying Petition To Compel

DOA: Neither Appellant Nor Respondents Were Able To Discover Copy Of A Written Agreement To Arbitrate It was undisputed that in the ordinary course of business, respondents required all employees to sign an arbitration agreement, and it was not clear why the appellant, Mr. Corselli “might have been an exception to this rule.” Apparently, the […]

Arbitration/Unconscionability/Employment: Second District, Division 8 Affirms Order Finding Arbitration Agreement Is Permeated By Unconscionability And Refusing Severance

Failure To Translate Relevant Contractual Provisions Into Spanish For Spanish-Speaking Employees Elevated This Case “To A High Degree Of Procedural Unconscionability”       Car wash employees brought a putative class action against their employer for wage and hour violations.  The trial court held the arbitration agreement was unconscionable and refused to enforce it.  Employer appealed.  Carmona […]

Arbitration/Pending Cases: Casas v. Carmax Is Now Certified For Publication

Second District, Division 2 Opinion Reversing Trial Court’s Order Denying CarMax’s Motion To Compel Arbitration Is Now Certified For Publication      On February 27, 2014, I posted about Casas v. CarMax Auto Superstores California LLC, Case No. B246392 (2nd Dist. Div. 2 Feb. 26, 2014) (Johnson, Chaney, Miller). At that time, the opinion, filed February […]

Arbitration/Waiver/Employment/Class Action/FAA Preemption: Second District, Division 2, Holds That Employee Can Be Compelled To Arbitrate A Private Attorney General Act Employment Claim Individually, Thereby Enforcing Class Action Waiver

Court Acknowledges That Private Attorney General Laws “May Be Severely Undercut By Application Of The FAA”       On March 12, at the end of my previous post, I commented “we are still in a somewhat fuzzy area regarding FAA preemption of California statutory rights to file a court action – especially in those instances where […]

Arbitration/Employment/Unconscionability/FAA Preemption: Second District, Division 4, Holds That Labor Code Section 229 Only Exempts Unpaid Wage Claim From Arbitration

And Employer Failed To Sustain Burden Of Proving That California Statutory Right Of Employee To Avoid Arbitration Of Unpaid Wages Claim Was Preempted By Federal Arbitration Act       Francis Capital Management LLC (FCM) appealed from an order denying its motion to compel Lane, a former employee, to arbitrate all his employment claims against FCM.  Lane […]

Arbitration/Employment/Enforceability: Second District, Division 2 Reverses Trial Court’s Order Denying CarMax’s Motion To Compel Arbitration

  Unilateral Right To Alter Or Terminate Agreement Does Not Necessarily Make It “Illusory”    Employee Casas sued his employer CarMax, alleging wrongful termination and related causes, prompting CarMax to move to compel arbitration.  However, the trial court denied CarMax’s motion to compel, buying its argument that the arbitration agreement was “illusory” because the Dispute […]