Category: Arbitration: Equitable Estoppel

Arbitration, Estoppel, Waiver: Failure To Timely Exercise Right To Baseball Arbitration Is “The Whole Ball Game”

  Court Of Appeal Rejects Waiver, Estoppel And Forfeiture Arguments Made By Lessor Who Failed To Timely Exercise Right To “Baseball Arbitration” In Rental Dispute.      Miss Myrtle Rowe holding a baseball bat.  March 14, 2010.  Library of Congress.      “Baseball arbitration” takes its name from salary arbitration in Major League Baseball, in which the […]

Arbitration, Nonsignatories, Equitable Estoppel and Third-Party Beneficiaries: Temporary Staffing Agency’s Arbitration Clause With Workers Did Not Allow Client With Whom Workers Were Placed To Compel Arbitration

  Third-Party Non-Signatory Owed Duties Under Labor Code To Plaintiff, Independent Of Plaintiff’s Contract.      Zepeda v. Paramount Citrus Packing Company LLC, F071593 (5th Dist. 7/14/16) (Pena, Levy, Smith) (unpublished) distinguishes two situations:  (1) a plaintiff whose relationship with a third-party non-signatory merely presumes the existence of a contract; and (2) a plaintiff whose rights […]

Arbitration, Employment: Second Dist., Div. 7 Reverses Judgment Denying Petition To Compel Arbitration And First Dist., Div. 4, Affirms Order Denying Employer’s Petition To Compel Arbitration

     Notwithstanding the trend in SCOTUS to uphold arbitration agreements, including waiver of class arbitration, our next two unpublished cases show that the California courts look closely at arbitration agreements, sometimes enforcing and sometimes not enforcing arbitration agreements.  On the same day, one California Court of Appeal reversed an order denying an employer’s effort to […]

Arbitration, Estoppel: Fifth District, Division Two Holds That Law Firm Is Judicially Estopped From Seeking Default Judgments, Because It Included Cause Of Action Seeking To Compel Arbitration

Presiding Justice Turner Respectfully Dissents.      The Fifth Circuit, Division Two, holds that because a law firm’s cause of action to compel arbitration with its client “admitted the existence of a binding agreement to arbitrate the fee dispute, the trial court’s jurisdiction over the merits of plaintiff’s claims was initially limited to a determination of […]

Arbitration, Nonsignatories, Equitable Estoppel: Nonsignatory Defendant Is Able To Compel Nonsignatory Plaintiff Because All The Claims Are “Inextricably Intertwined”

  Plaintiffs’ Pleading Allegations Didn’t Help Their Argument.       The somewhat anomalous circumstances in this case allowed a nonsignatory defendant to arbitrate its claims with a nonsignatory plaintiff.  O’Donnell Strategic Industrial REIT v. Super. Ct., G049498 (4/3 Jan. 28, 2015) (Thompson, Bedsworth, Moore) (unpublished).        In a dispute concerning the setting up and operation of […]

Arbitration/Nonsignatories/Equitable Estoppel: Dentist Who Voluntarily Arbitrated But Did Not Sign Arbitration Agreement Was Not Equitably Estopped From Refusing To Arbitrate Again

In Which The Trial Court Sums It Up Neatly For The Court Of Appeal.      In Chan v. Delta Dental of California, A138402 (1st Dist. Div. 2 July 10, 2014) (Kline, Richman, Brick) (unpublished), a dental service provider sought to enforce an unsigned arbitration agreement based on an arbitration agreement that a dentist had not […]

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/Nonsignatories/Equitable Estoppel/Agency/Third Party Beneficiaries: Ninth Circuit Holds Parties Remain Bound By Agreements They Made And Not By Agreements They Didn’t Make

Many “Imaginative Arguments” Rejected To Get To Simple Conclusion      I’ve had the unpleasant experience of purchasing electronic equipment, only to discover later that the seller had booked the sale as a lease.  Therefore, our next case, Murphy v. DirectTV, Inc., No. 11-57163 (9th Cir. July 30, 2013) (Wardlaw, J. author 3:0) (published) struck a […]

Arbitration/3rd Party Beneficiaries/Equitable Estoppel: 9th Circuit Holds District Court Correctly Concluded Defendant Could Not Invoke Arbitration Clause As 3rd Party Beneficiary or Through Equitable Estoppel

Defendant Admitted It Did Not Enter Into Contract With Student To Provide Him With Debt Relief Services      Student loan debt is an area of our economy ripe to generate cases on arbitration and class action.  See for example my April 12, 2013 post about Kilgore v. Keybank, No. 09-16703 (9th Cir. April 11, 2013), […]

Arbitration/Nonsignatories/Equitable Estoppel: Ninth Circuit Puts Brakes On Toyota’s Attempt To Compel Prius Plaintiffs To Arbitrate Their Claims

District Court Could Decide Whether Nonsignatory Could Compel Arbitration      Toyota has been enmeshed in arbitration concerning the ABS braking system of its 2010 Prius.  In Kramer v. Toyota Motor Corporation, et al., Case No. 12-55050 (9th Cir. January 1, 2013) (Quist, D. J., author 3-0) (published), owners of 2010 Priuses, parties to arbitration agreements […]