Category: Arbitration: Unconscionability

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Motion To Compel Arbitration (Published), And 4th District, Div. 3 Affirms Order Denying Motion To Compel Arbitration (Unpublished) In Employment Cases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/Employment/Unconscionability/Severance: Court Affirms Order Denying Employer’s Petition To Compel Arbitration

  Permeated With Unconscionability, Agreement Did Not Require Severance.      Mr. Ryan, an employee in the construction industry, claimed that he was fired in a retaliatory move by his employer.  The employer petitioned to compel arbitration.  The trial court denied the request, finding the mandatory employment arbitration agreement contained unconscionable provisions, and refusing to sever […]

Arbitration/Unconscionability: Court of Appeal Concludes That One-Sided “Take It Or Leave It” Agreement With Financially Battered Spanish Speaking Parties Is Unconscionable

Dissenting Justice Would Have Waited For Further Guidance From Supreme Court On Pending Cases      Nine plaintiffs sued their mortgage foreclosure consultant and others for fraud, breach of contract, and other claims, alleging they were duped into signing their agreements and lost money when they paid for services that were never rendered.  Defendants successfully petitioned […]

Arbitration/Unconscionability/Employment: Second District, Division 8 Affirms Order Finding Arbitration Agreement Is Permeated By Unconscionability And Refusing Severance

Failure To Translate Relevant Contractual Provisions Into Spanish For Spanish-Speaking Employees Elevated This Case “To A High Degree Of Procedural Unconscionability”       Car wash employees brought a putative class action against their employer for wage and hour violations.  The trial court held the arbitration agreement was unconscionable and refused to enforce it.  Employer appealed.  Carmona […]

Arbitration/Automobiles/Severability/Unconscionability/FAA: Case Is Remanded So Trial Court May Determine Whether Unconscionable Provisions In Automobile Installment Sale Contract Are Severable

  Sixth District Does Agree That Federal Arbitration Act Preempts California Consumers Legal Remedies Act, So Class Action Waiver In Arbitration Clause Is Enforceable      Jalopy that has seen better days.  Carol M. Highsmith, photographer.  Library of Congress.       An arbitration clause that is “permeated with unconscionability” need not be enforced.  Here, the scorecard in […]

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/Employment/Unconscionability/FAA Preemption: Second District, Division 4, Holds That Labor Code Section 229 Only Exempts Unpaid Wage Claim From Arbitration

And Employer Failed To Sustain Burden Of Proving That California Statutory Right Of Employee To Avoid Arbitration Of Unpaid Wages Claim Was Preempted By Federal Arbitration Act       Francis Capital Management LLC (FCM) appealed from an order denying its motion to compel Lane, a former employee, to arbitrate all his employment claims against FCM.  Lane […]

Arbitration/Unconscionability: First District, Division 1, Finding Agreement To Arbitrate Was Not Unconscionable, Reverses Trial Court

“Yellow Flags” In Arbitration Clause Functioned As Friendly Warnings, And Did Not Make Clause Unconscionable      Plaintiff/Respondent Boese, pursuant to a subscription agreement, invested several hundred thousand dollars with Couch Oil & Gas, Inc., and sued for securities violations.  After the trial court denied Couch Oil’s petition to compel arbitration on the ground that the […]

Unconscionability/Preemption/Class/Consumers: Ninth Circuit Upholds Denial Of Arbitration In Two Cases

      Ninth Circuit Judge William Fletcher is the author of two recent Ninth Circuit opinions affirming district court denials of motions to arbitrate against class action plaintiffs. Like his mother, the distinguished late Ninth Circuit Judge Betty Binns Fletcher, W. Fletcher was born in the State of Washington, and the next two cases involve Washington […]

Arbitration/Unconscionability/Automobiles: Fourth District, Div. 3 Finds Arbitration Provision In Common Automobile Sales Contract To Be Unconscionable

  An Opportunity To Enjoy Some Vintage Justice Bedsworth      The unconscionability issue concerning the Retail Installment Sales Contract in the next case is currently pending before the California Supreme Court In Sanchez v. Valencia Holding Co., 201 Cal.App.4th 74 (2011), review granted March 21, 2012 (S199119) and several related cases.  In an opinion authored […]