Category: Arbitration: Standard of Review

Arbitration/Standard of Review/CCP 1281.2/Nonsignatories: Nonsignatories Created Possibility of Conflicting Rulings And Also There Was Evidence That Aged Plaintiff Never Agreed To Arbitrate

Standard of Review Was Crucial To Affirmance of Trial Court’s Order Denying Motion to Compel Arbitration      What a difference the standard of review can make.       Plaintiff Thiel, an investor, sued MKA Real Estate Qualified Fund I, LLC for investment mismanagement.  Several investment advisors, as well as real estate developers, were named as co-defendants.  […]

Arbitration/Unconscionability/Severability/Standard of Review: Law Firm Partnership Agreement That Is Functionally An Employment Agreement Is Subject To Armendariz Unconscionability Analysis

  Court of Appeal Rejects Employer’s Contention that AT&T Mobility v. Concepcion Overruled Armendariz Unconscionability Analysis      Plaintiff Erika Brenner, an attorney, sued her “employer” Glenn Johnson Law, LLP and its principal, attorney Glenn Johnson, for wrongful discharge and other employment-related claims.  Defendants moved to compel arbitration under a contractual arbitration provision.  Brenner opposed, arguing […]

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/Preemption/Standard of Review: Federal Arbitration Act Preempts Consumer Legal Remedies Act’s Prohibition Against Class-Action Waivers

  Fourth District, Division 3 Reverses Denial of Petition to Compel Arbitration and Remands to Consider Unconscionability Challenge      Plaintiff Caron, who experienced difficulties with her certified preowned Mercedes Benz, sued Mercedes Financial and Mission Imports for relief under the Consumer Legal Remedies Act (CRLA), the Automobile Sales Finance Act, and unfair competition law.  Defendants […]

Arbitration/Waiver/Burden of Proof: Substantial Evidence Supported Waiver of FINRA Arbitration

  St. Agnes Factors Weighted In Favor of Finding of a Waiver      The leading California case for determining whether a waiver of the right to arbitrate has occurred is St. Agnes Medical Center v. PacifiCare of California, 31 Cal.4th 1187 (2003). St. Agnes provides a multi-factor test that the court handily applied in Alspaugh […]

Arbitration/Fees/Waiver/Severability/Standard of Review : In Elder Abuse Case, Court of Appeal Affirms Severance From Arbitration Clause of Waiver of Plaintiff’s Statutory Right to Recover Attorney’s Fees

  Fifth District Explains That By Submitting A Dispute to An Arbitral Forum, A Party Does Not Necessarily Forgo Substantive Statutory Rights      Plaintiff Ruth Chappell (replaced by her trustee Bickel after she died) sued an assisted living facility, Sunrise Assisted Living, for Elder Abuse. Chappell’s written agreement with Sunrise included an arbitration clause specifying […]

Arbitration/Nonsignatories/Enforcement: Second District, Division 7 Affirms Decision That Plaintiff Was Not Bound By Arbitration Provision In “Close Case”

  Outcome Depended On Capacity In Which Signatory Signed      The trial court determined that Plaintiff Allen Othman was not a party to a contract containing an arbitration provision in an agreement, and therefore was not bound to arbitrate his claims against Zions First National Bank. Mr. Othman had tried to purchase a property through […]

Arbitration/Standard of Review: Trial Court Properly Vacated Arbitraiton Award, In Light of Unfair Procedure and Lack of Actual Notice

  Fundamental Fairness Issue Involving Lack of Notice Resulted in De Novo Standard of Review      Plaintiff and Respondent Roland Hansalik signed a promissory note with Wells Fargo Advisors, LLC, with a provision calling for arbitration before the Financial Industry Regulatory Authority (FINRA). Then Mr. Hansalik moved to Switzerland. Wells Fargo initiated arbitration through FINRA, […]

Arbitration/Standard of Review: Fourth District, Division Two Holds Arbitrator Did Not Exceed Authority In Ruling County Employee Was Terminated Without Just Cause

  Court of Appeal Also Rejects Public Policy Argument Put Forward By County for Vacating Arbitrator’s Award      The County of Riverside terminated the Respondent, Ms. Matheson, a network administrator, for allegedly accessing email of the District Attorney’s Office without authorization. Pursuant to the procedure agreed to between the County and Ms. Matheson’s labor union, […]

Arbitration/Standard of Review/Fees: Second District, Division 7 Reverses Orders Awarding Attorney Fees, and Otherwise Confirms Arbitration Award

       You know that this one must have been a real kerfuffle, because the Court of Appeal quotes the arbitrator: “Lots of fiercely fought and expensive litigation followed, including this arbitration.” Liner Grode Stein Yankelevitz Sunshine Regenstreif & Taylor v. Rotondo, B221056 & B223528 (2nd Dist. Div. 7 March 22, 2012) (Woods, Acting P.J.) […]