Category: Arbitration: Unconscionability

Arbitration, Unconscionability: Unconscionable Terms In Employment Agreement Vitiated Separate Arbitration Agreement

The Two Agreements Were Read Together As One Agreement.         In Silva v. Cross Country Healthcare, Inc., B337435 (2/5  6.13/25) (Hoffstadt, Moor, Kim), employees Isabel Silva, Alejandro Garcia, and Janai Velasco challenged their employer’s attempt to compel arbitration of their wage-and-hour and related claims. Each plaintiff had signed two agreements at hiring: (1) an Arbitration […]

Unconscionability: Fourth Dist. Div. 3 Agrees Arbitration Agreement Was Procedurally and Substantively Unconscionable

The Opinion Applies Established California Unconscionability Law.         In Velarde v. Monroe Operations, LLC, 111 Cal.App.5th 1009 (4/3 6/6/25) (Sanchez, Moore, Motoike), the California Court of Appeal affirmed denial of a motion to compel arbitration. Newport Healthcare required new hire Karla Velarde to sign an arbitration agreement as a condition of employment, presenting it among […]

Discovery: Sixth District Holds Arbitration Agreement Is Enforceable Where Discovery Rules Are Lenient Enough

The Court Of Appeal Distinguished Between The More Lenient Discovery Provisions In Vo And The Tougher Discovery Restrictions In Aixtron.         In Vo v. Technology Credit Union, H051619 (6th Dist.  2/4/25) (Greenwood, Grover, Danner), the California Court of Appeal reviewed an arbitration agreement signed by Thomas Vo, an employee of Technology Credit Union (TCU). After […]

Unconscionability: Fourth District Div. 3 Finds Arbitration Provision Presented In English To Spanish Speaking Legal Client Was Not Enforceable

February 10, 2025 · Arbitration: Unconscionability

Presenting An English Contract To A Spanish Speaking Legal Client Illiterate In English Was Problematic         Justo Malo Sanchez filed a legal malpractice lawsuit against Consumer Defense Legal Group and its representatives, alleging issues with the firm's handling of his case. The retainer agreement he signed contained an arbitration clause, but Sanchez argued that the […]

Mass Arbitration: 9th Circuit Holds Mass Arbitration Approach Employed By Ticketmaster Is Unconscionable

Mass Arbitration Model For Batching Together Claims With Common Legal Or Factual Issues Held To Be Unconscionable.         The Ninth Circuit affirmed the district court's denial of Live Nation and Ticketmaster’s motion to compel arbitration in a Sherman Act antitrust class action. Skot Heckman et al. v. Live Nation Entertainment, Inc.; Ticketmaster, LLC, No. 23-55770 […]

Unconscionability, Severance: 9th Maj. Says Arb Agreement Is Unconscionable; Dissent Favors Severance

To Sever Unconscionable Provisions Or Not To Sever . . . That Is The Question.         The Ninth Circuit affirmed the district court’s decision denying USF Reddaway, Inc.’s motion to compel arbitration, finding the agreement procedurally and substantively unconscionable under California law. The court held the arbitration agreement was moderately procedurally unconscionable due to its […]

Severability: Cal Supreme Court Explains There Is No Bright Line For Severing Unconscionable Provisions

Multiple Unconscionable Provisions Does Not Necessarily Make An Arbitration Agreement Unenforceable.         In Ramirez v. Charter Communications, Inc., No. S273802 (S.Ct. 7/15/24) (Corrigan, J.), Angelica Ramirez, a former employee of Charter Communications, sued the company for employment discrimination, harassment, and retaliation. Charter sought to compel arbitration based on an agreement Ramirez signed during her onboarding. […]

Arbitration, Unconscionability: 3rd District Agrees That American Automobile Association Arbitration Agreement Is Unconscionable

February 11, 2024 · Arbitration: Unconscionability

Court Affirms Order Denying Motion To Compel Arbitration.         "On a sliding scale, the procedural and substantive unconscionability as to this arbitration agreement is high." Hasty v. American Automobile Assn. of Northern Cal., Nev. & Utah , C097674 (3rd Dist.  pub. 1/6/24) (Robie, Mauro, Krause). The order denying the AAA's  petition to compel arbitration is […]

Delegation: Ninth Circuit Concludes That Delegation Clause Is Enforceable, Regardless Of Whether Arbitration Clause Is Found To Be Enforceable

Nesting dolls (Matryoshka dolls). Wikipedia. Published under GNU Free Documentation License, Version 1.2, and any subsequent versions.         We can analogize the next case to a nesting doll problem. The delegation clause in an arbitration agreement (Agreement) is a mini-agreement nested in the Agreement. The Agreement is nested in an employment contract, consumer contract, or […]

Unconscionability: Second District, Div. 8 Holds That Illegible Contract Is Fair, And Therefore Not Unconscionable

Majority Of Panel Holds That Substantive Unconscionability Was Missing. Justice Stratton Dissents.          Writing for the majority, Justice John Shepard Wiley Jr. explains that the above contract is enforceable, requiring the plaintiff employee to arbitrate her dispute. Though the document is manifestly illegible, Justice Wiley concludes that the contract is fair. Therefore, there is no […]