Category: Uncategorized

Arbitration, Burden of Proof, Authentication, Employment: Trial Court Found By Preponderance Of Evidence That Employer Failed To Prove Employee Signed Arbitration Agreement

January 25, 2019 · Uncategorized

Arbitration Agreement Had Signature With Employee's Name, But Employer Failed To Carry Burden Of Authentication.     Tropicale appealed the denial of its motion to compel arbitration against employee Garcia. Ana Garcia v. Tropicale Foods, Inc., E069024 (4/2  1/22/19) (Raphael, Miller, Slough) (not certified for publication). The issue was whether Tropicale failed to prove by […]

Arbitration, Gateway Issues, Delegation: USCA 4th Circuit Holds That Incorporation Of JAMS Rules Delegates Questions Of Arbitrability To Arbitrator

December 21, 2017 · Uncategorized

But There Is A Dissent . . .          Simply Wireless Inc. v. Mobile US Inc ., Nos. 16-1123, 16-1166 (4th Cir.  12/13/17) resulted in an interesting majority opinion authored by Judge Wynn, with Judge Harris, joining, and a dissent by Judge Floyd.  As a result, I have strayed beyond my usual beat of covering […]

Arbitration, Standard Of Review: Trial Court’s Order Denying Motion To Compel Arbitration Is Affirmed Where Trial Court Had To Rule On “Intensely Factual And Hotly Contested Issues”

November 19, 2017 · Uncategorized

"This Appeal Comes Down To Application Of The Standard Of Review."         While I have blogged many times about cases in which the Court of Appeal has reversed an order denying a motion  to compel arbitration, this is not one of those cases.  T3 Motion, Inc. v Tsumpes, G053654 (4/3  11/14/17) (Fybel, Bedsworth, Thompson) (unpublished).  […]

Arbitration, Unconscionability: 1/3 CCA Concludes Arbitration Agreement In Employee Contract Is Procedurally and Substantively Unconscionable

October 29, 2017 · Uncategorized

Court Of Appeal Affirms Trial Court's Order Denying Employer's Motion To Compel Arbitration.          Notwithstanding the trend in the SCOTUS, (and as the immediately preceding post demonstrates, in Congress too), to enforce arbitration agreements, many California Courts of Appeal continue to vigilantly scrutinize arbitration agreements for unconscionability.  Baxter v. Genworth North America Corporation, et al, A144744 […]

Miscellaneous: Mediation Quality

August 13, 2017 · Uncategorized

ABA Section of Dispute Resolution — Task Force on Improving Mediation Quality Final Report.         In 2008, the ABA Section of Dispute Resolution issued a Final Report on mediation quality.  This report is available on-line.         The Task Force narrowly focused on mediation quality in private practice civil cases where the parties are usually […]

Arbitration/Agents: Third District Rules That Care Facility For Elderly Could Not Enforce Arbitration Provision, Because Sister’s Power Of Attorney Did Not Provide Authority To Make Health Care Decisions

June 15, 2017 · Uncategorized

Trial Court And Court Of Appeal Agreed That The Residential Care Facility For The Elderly Provided Health Care.     Hutcheson v. Eskalon Fountainwood Lodge, C074846 (3rd Dist.  6/14/17) (Nicholson, Mauro, Duarte), is one of many cases in which a care facility for the elderly seeks to enforce an arbitration provision after an elderly person in […]

Arbitration, Automobiles, and Construction Of Agreement: Agreement Providing For Right Of Party To Request “A New Arbitration” Is Effective Even In Arbitration Forum That Does Not Provide Appeal Rules

February 23, 2017 · Uncategorized

The Arbitration Clause Analyzed By The Court Is Common In Automobile Sales Contracts.     The Arbitration Clause analyzed in Raczynski v. Daland Nissan, Inc., et al., A146992 (1/5 2/15/17) (Bruiniers, Jones, Needham) (unpublished), provides that the arbitrator’s award “shall be final and binding on all parties, except that in the event the arbitrator’s award for a […]