Category: Arbitration: Enforceability

Arbitration/Employment/Unconscionability: Perplexed Court Of Appeal Offers Pointers On Drafting An Enforceable Arbitration Provision

How To Avoid Drafting An Unconscionable Arbitration Agreement.      We usually summarize opinions, but here, the Court of Appeal does a good job itself of summing up how to draft an enforceable arbitration provision in an employment agreement.  The case is Woods v. JFK Memorial Hospital, Inc., G050286 (4/3 Oct. 30, 2014) (Moore, Rylaarsdam, Thompson) […]

Arbitration/Employment/Enforceability: Fifth District Holds Agreement For Advisory Arbitration Is Not Enforceable Under The California Arbitration Act

But Federal Law Is Not So Clear      The issue in Operating Engineers Local Union No. 3 v. City of Porterville, Case No. F067635 (5th Dist. Oct. 2, 2014) (Kane, Levy, Detjen) (unpublished) is whether an agreement between a city and a union to submit an employment dispute to advisory arbitration is enforceable under the […]

Arbitration/Nonsignatories: Big Surprise–Parties That Failed To Initial Arbitration Provision As Required By The Express Language Of The Provision Could Not Be Compelled To Arbitrate

Appellants’ Argument That There Was An “Implied Oral Understanding” Didn’t Cut It With The Court Of Appeal      The arbitration clause in our next case began:  “NOTICE:  BY INITIALING IN THE SPACE BELOW YOU ARE AGREEING TO HAVE ANY DISPUTE ARISING OUT OF THE MATTERS INCLUDED IN THE ‘ARBITRATION’ PROVISION DECIDED BY NEUTRAL ARBITRATION . […]

Consumer Arbitration/Employees/Enforceability/ Fees: CCP 1284.3 Prohibits Fee Shifting In Employee Arbitrations But Not On The Facts Of This Case

Court of Appeal Was Unable To Find Precedent On Whether CCP 1284.3, Pertaining To Consumer Arbitrations, Applies To Employer-Employee Arbitrations, And Reaches Its Own Conclusion      On March 12, 2014, I posted about an earlier Court of Appeal decision involving the same parties and the same arbitration agreement as here, in which the Court held […]

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Motion To Compel Arbitration (Published), And 4th District, Div. 3 Affirms Order Denying Motion To Compel Arbitration (Unpublished) In Employment Cases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 […]

Arbitration/Nonsignatories: Ninth Circuit Raps Browsewrap Contract, Affirming Order Denying Motion To Compel Arbitration

A Progression:  From Shrink Wrap To Browsewrap To Clickwrap Contracts       Above:  Shrink wrapped helicopters to be shipped to Iraq.  US Navy photo, Bart Jackson.  Wikimedia Commons.      In a case that will be important to e-commerce merchants, and on-line consumers, a Ninth Circuit panel holds that Barnes & Noble’s website provided insufficient notice of […]

Arbitration/Enforceability/Nonsignatories: Defendant Fails To Sustain Burden Of Showing Plaintiff Signed Arbitration Agreement

Declarants Lacked Personal Knowledge      If you want to compel arbitration, it sure helps to have a signed arbitration agreement, as defendant Wells Fargo discovered in Bachenheimer v. Wells Fargo Bank, N.A., B251980 (2nd Dist. Div. 5 July 21, 2014) (Turner, Mosk, Mink) (unpublished).       Plaintiff, who suffered from traumatic brain injury, invested her savings […]

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/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/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 […]