Judge: Alison Mackenzie, Case: 23STCV04487, Date: 2023-11-16 Tentative Ruling

Case Number: 23STCV04487    Hearing Date: November 16, 2023    Dept: 55

NATURE OF PROCEEDINGS:  Motion of Defendant to Compel Arbitration.  Motion of Plaintiff to Compel Deposition Attendance and Production of Documents by Defendant Hyundai Motor America’s Person Most Knowledgeable; and Request For Sanctions In The Amount Of $2,566.75.

 

The motion to compel arbitration is granted. 

The motion to compel deposition attendance is ordered off calendar because the case is stayed pending arbitration.

Plaintiff and Defendant shall arbitrate the controversies between them, including the entire Complaint, and the motion to compel the deposition, in accordance with their agreement to arbitrate.  This entire case is stayed until such arbitration has been completed. The Court will set a post-arbitration status conference.

 

 

On 3/1/23, Plaintiff filed a Complaint alleging that Defendant Hyundai Motor America breached a warranty that it had attached to a new 2022 Hyundai Tucson leased to Plaintiff by retail seller Keyes Hyundai of Van Nuys, because the vehicle had serious defects including battery defects and check engine warning light illumination. Based on these alleged defects, Plaintiff sued Defendant under the Song-Beverly Consumer Warranty Act for breach of the express and implied warranties that Defendant furnished to Plaintiff in connection with the lease of the Subject Vehicle.

Defendant filed a motion to compel contractual arbitration and to stay this action.  Plaintiff opposes arbitration, based on Defendant not being a party to the car lease, and Defendant having unconscionably placed a warranty agreement in the leased vehicle.  Additionally, Plaintiff filed a motion to compel a deposition of Defendant’s person most knowledgeable, after nonattendance on the noticed date of 9/22/23, and Plaintiff seeks sanctions in the amount of $2,566.75.  Defendant expresses willingness to meet and confer in good faith and to set a mutually agreeable deposition date.

Motion to Compel Arbitration

Lease

Regarding Defendant’s standing to seek enforcement of the nonparty’s lease agreement, the Court notes that the Complaint admits some agency relationship between nonparty Keyes Hyundai and Defendant (Complaint, ¶18), and some participation in the leasing by subsidiaries related to Defendant as parent  (Ali Ameripour Decl., ¶ 5, filed 6/1/23).  However, because the Court compels arbitration based upon the moving Defendant’s own arbitration provisions in its warranty, the Court need not apply the arbitration provisions of the nonparty’s lease agreement as discussed in recent case law including, for example, Ford Motor Warranty Cases (2nd Dist. 2023) 89 Cal.App.5th 1324, 1334 and Jaquelyn Yeh v. Superior Ct. (1st Dist. 2023) 95 Cal.App.5th 264, 294.     

Warranty

Defendant contends that Plaintiff must arbitrate the claims in this case pursuant to the parties’ agreement to arbitrate in the warranty. Plaintiff leased the subject vehicle with a Motor Vehicle Lease Agreement requiring Plaintiff to resolve any disputes relating or arising out of the Lease, the Vehicle, or any resulting relationship by binding arbitration (Motion, p. 5).  Defendant’s warranty accompanied the lease, and the warranty also has an arbitration provision. (Id., see also Ali Ameripour Decl., ¶ 6, Ex. 3.) Plaintiff argues that the warranty was unconscionable and take-it-or-leave-it.

“[F]reedom to choose whether or not to enter a contract of adhesion is a factor weighing against a finding of procedural unconscionability.”  Gentry v. Sup. Ct. (2007) 42 Cal. 4th 443, 470, abrogated on other grounds by Iskanian v. CLS Transportation Los Angeles, LLC (2022) 59 Cal. 4th 348, 360; and Viking River Cruises, Inc. v. Moriana (2022) 142 S. Ct. 1906.

Here, the Court finds that the moving party’s warranty arbitration provisions are enforceable and not unconscionable, because the warranty allowed Plaintiff the ability to take 30 days to read, to have professionally reviewed, and to opt out via an easy email address, via language such as the following excerpt:

IF YOU PURCHASED OR LEASED YOUR VEHICLE IN CALIFORNIA, YOUR WARRANTY IS MADE SUBJECT TO THE TERMS OF THIS BINDING ARBITRATION PROVISION BY USING THE VEHICLE, OR REQUESTING OR ACCEPTING BENEFITS UNDER THIS WARRANTY, INCLUDING HAVING ANY REPAIRS PERFORMED UNDER WARRANTY, YOU AGREE TO BE BOUND BY THESE TERMS. IF YOU DO NOT AGREE WITH THESE TERMS, PLEASE CONTACT US AT OPT-OUT@HMAUSA.COM WITHIN THIRTY (30) DAYS OF YOUR PURCHASE OR LEASE TO OPT-OUT OF THIS ARBITRATION PROVISION.

(“DECLARATION OF ALI AMERIPOUR IN SUPPORT OF DEFENDANT’S MOTION TO COMPEL BINDING ARBITRATION,” filed 6/1/23, ex. 3 (“Owner’s Handbook & Warranty Information”), § 4, p. 14).  [Emphasis added.]

The opposing attorney declaration contains no evidence to the contrary.  Further, the opposition does not describe any substantive unconscionability by only generally concluding it contains harsh and one-sided terms.  Published opinions have addressed specific types of unconscionable terms that the opposition does not discuss.  Further, reading the warranty arbitration provisions reveals no cognizable, unconscionable terms.  Claims are subject to arbitration and not unconscionable, if there are provisions for arbitrator neutrality, discovery, written decisions, and expense limits.  Armendariz v. Foundation Health Psychcare Services, Inc. (2000) 24 Cal.4th 83, 96-121.

Hence, the Court finds and concludes that the warranty agreement was not take-it-or-leave it and was not procedurally or substantively unconscionable. 

Motion to Compel Deposition

The motion to compel a deposition argues that Plaintiff attempted multiple times through meet and confer efforts to get Defendant’s counsel to provide an alternate date set for the deposition, but Defendant has not provided any alternate dates.  Defendant contends the opposite, that Plaintiff failed to meet and confer in good faith to set a mutually agreeable deposition date.

Here, the Court compels this case into arbitration and does not decide the discovery motion.  "After a petition to compel arbitration has been granted and a lawsuit stayed, 'the arbitrator takes over. It is the job of the arbitrator, not the court, to resolve all questions needed to determine the controversy.'”  MKJA, Inc. v. 123 Fit Franchising, LLC (2011) 191 Cal.App.4th 643, 662.  “[A]ll discovery disputes arising out of arbitration must be submitted first to the arbitral, not the judicial forum.”  Berglund v. Arthroscopic & Laser Surgery Center of San Diego, L.P. (2008) 44 Cal.4th 528, 535 (citing CCP §1283.05).

Conclusion

The Court grants the motion to compel arbitration as to this entire action and discovery.