Category: Arbitration: Employment

Arbitration/Waiver: Employer That Quickly Asserted Right To Arbitrate After Concepcion Was Decided Did Not Waive Right To Arbitrate

Timing Is Everything      Plaintiff Reyes, a security officer, filed a class complaint alleging wage and hour violations against Liberman Broadcasting, Inc. (LBI).  The trial judge denied a motion by LBI to compel arbitration, on the grounds that the employer failed to properly and timely assert its right to arbitrate.  LBI appealed the trial court’s […]

Arbitration/Employment/Waiver/Burden of Proof/Construction: Because Collective Bargaining Agreement Did Not “Clearly And Unmistakably” Waive Plaintiffs’ Right to Bring Statutory Claims In Judicial Forum, Employees Did Not Waive Their Rig

Denial of Motion to Compel Arbitration Hinges on Burden of Proof and Existence of Statutory Rights      One of the “hot topics” we have posted about is whether the right to sue in court can be waived when the rights at issue are statutory rights.  See our June 5, 2012 post on Iskanian v. CLS […]

Arbitration/Class Action/Waiver/Employment: 4th District Division 1 Endorses De-Gentrification But Concludes That Gentry v. Superior Court Is Stare Decisis In California – For Now

At Issue for Employers and Employees:  Classwide Arbitration or Individual Arbitration?      In an April 25, 2012 post, we said the rule in Gentry v. Superior Court, 42 Cal.4th 443 (2007), allowing for invalidation of a class arbitration waiver where nonwaivable statutory rights are at issue, manages to maintain a “toehold”.  We suggested Gentry, like […]

Arbitration/Employment/Enforceability/Standard of Review/Public Policy: Ninth Circuit Refuses to Vacate Arbitration Award Prohibiting Retired Football Player from Pursuing Workers’ Comp Claims Under California Law

  Football Player Bruce Matthews Did Not Allege Sufficient Contacts With California To Show Workers’ Comp Claim Came Within Scope of California’s Workers’ Comp Regime      Bruce Matthews, a former American college and professional football player, was an offensive lineman in the NFL for 19 seasons.  He played college football for  USC, was an All-American, […]

Arbitration/Employment/Unconscionability: Second District, Division 5 Affirms Denial of Petition to Arbitrate Wrongful Termination Employment Dispute

  Majority Opinion Identified Many State Law Contractual Problems With Arbitration Provision      Plaintiff Sparks sued for wrongful termination, and employer Vista Del Mar Child and Family Services petitioned to arbitrate the dispute.  The trial court denied the petition, and the employer appealed.  Sparks v. Vista Del Mar Child and Family Services, Case No. B234988 […]

Arbitration/Employment/Class Actions/Enforceability: First District, Division 1 Affirms Order Compelling Employee To Individual Arbitration

Viability of Gentry v. Superior Court is Sidestepped By Court of Appeal      Plaintiff/employee Lorena Nelsen filed a putative class action lawsuit against her former employer LPI for multiple Labor Code violations.  Because Nelsen signed an arbitration agreement when she was hired, the employer, LPI moved, successfully, to compel arbitration with Nelsen all alone.  Nelsen […]

Arbitration/Enforceability/Employment: Requiring Employee To Agree To Arbitration Provision Is Not By Itself Wrongfully Coercive, Despite Loss Of Right To A Jury

  Labor Code Section 206.5 Prohibits Employer From Obtaining Release of Claim For Wages Under Specified Circumstances, But Does Not Preclude Employee From Waiving Right to Jury By Agreeing To Arbitrate      The scenario is familiar: Employee (Pulli) sues employer (Pony International, LLC), for wrongful termination and other claims. Because employee signed an arbitration provision, […]

Arbitration/FAA/Waiver/Employment: Fourth District, Div. 2, Affirms Denial of Petition to Arbitrate in Area of the Law It Describes as “Fluid and Volatile”

Split of Opinion Continues About Arbitrability of State Statutory Labor Claims “Once more unto the breach, dear friends, once more.” (Henry V, Act 3, Scene 1).      Hoover v. American Income Life Insurance Company, Case No. E052864 (4th Dist. Div. 2 May 16, 2012) (Codrington, J., author) (certified for publication) underscores a split in the […]

Arbitration/Federal Preemption/Class Actions/Employment: Second District, Division 2 Broadly Applies Federal Preemption in Labor Code Violation Case to Uphold Arbitration

Vindication of Statutory Rights Loophole to Arbitration Is Closed      In an April 25, 2012 post, we suggested, based on Kinecta Alternative Financial Solutions, Inc. v. Superior Court of Los Angeles County, (2012) (partially published) (District 2, Div. 3), that “the rule in Gentry [42 Cal.4th 443 (2007)] allowing for invalidation of class arbitration waiver […]

Arbitration/Employment/Unconscionability: First District, Division 3 Affirms Superior Court’s Refusal To Compel Arbitration Of Claims By Carpet Installers

The Arbitration Provision is Unconscionable, and Concepcion Does Not Change the Analysis      “Unconscionability” may sound like an abstract legal principle, but it usually entails a very fact-specific analysis.  Try out these facts:  plaintiffs are carpet layers; they speak Spanish; contracts were presented to them only in English; they have difficulty reading simple written English; […]