Judge: Alison Mackenzie, Case: 24STCV11031, Date: 2024-10-16 Tentative Ruling



Case Number: 24STCV11031    Hearing Date: October 16, 2024    Dept: 55

NATURE OF PROCEEDINGS: Hearing on Defendant’s Motion to Compel Arbitration

 

Defendant’s Motion to Compel Arbitration is granted.

 

BACKGROUND

Plaintiff Christine Haxton brought this action against Defendant ACSC Management Services, Inc., alleging claims related to her employment by Defendant. 

The motion now before the Court is Defendant’s Motion to Compel Arbitration.

 

EVIDENTIARY OBJECTIONS

The Court rules on Plaintiff’s evidentiary objection as follows:

Objection 1: Overruled

Objection 2: Overruled

Objection 3: Overruled

Objection 4: Overruled

Objection 5: Overruled

Objection 6: Overruled

Objection 7: Overruled

Objection 8: Overruled

Objection 9: Overruled

Objection 10: Overruled

 

LEGAL STANDARD

“On petition of a party to an arbitration agreement alleging the existence of a written agreement to arbitrate a controversy and that a party to the agreement refuses to arbitrate that controversy, the court shall order the petitioner and the respondent to arbitrate the controversy if it determines that an agreement to arbitrate the controversy exists….” Code Civ. Proc, § 1281.2. “The party seeking arbitration bears the burden of proving the existence of an arbitration agreement, and the party opposing arbitration bears the burden of proving any defense, such as unconscionability.” Pinnacle Museum Tower Assn. v. Pinnacle Market Development (US), LLC (2012) 55 Cal.4th 223, 236.

 

ANALYSIS

A. Governing Law

Defendant seeks to enforce two arbitration agreements, one Plaintiff physically signed in 2018 and another allegedly signed electronically in 2019.  Both agreements specify that they are governed by the Federal Arbitration Act (FAA). Declaration of Steven Wicker (Wicker Decl.), Ex.1 at p. 7, sec. 8; Ex. 2 at p. 7, sec. 8.

B. 2018 Agreement

Plaintiff argues that the 2018 Arbitration Agreement is invalid because it contained a provision allowing Defendant to “unilaterally make changes to this Arbitration Agreement” and that by proposing the 2019 Agreement, which contains an integration clause, Defendant exercised its power to rescind the earlier agreement. Wicker Decl., Ex. 1 ¶ 8, Ex. 2 ¶ 8.

This argument is frivolous. Plaintiff’s quote of the 2018 Agreement does not reflect the limited nature of Defendant’s authority to make changes. The provision says, “the Club may unilaterally make changes to this Arbitration Agreement that are favorable to [Plaintiff] in order to conform to, or that are consistent with, court decisions or legislation; provided, however, that any such changes shall take effect only after 30 days’ prior notice to [Plaintiff].”   Wicker Decl. Ex. 1, sec. 8. Moreover, Plaintiff does not explain why the Court should treat the 2019 Agreement as a notice of unilateral modification rather than, by its plain terms, a bilateral contract requiring Plaintiff’s acceptance to be binding.  The integration clause only invalidates the 2018 Agreement if the 2019 Agreement was validly signed. Plaintiff does not dispute that she signed the 2018 Agreement. Therefore, the 2018 Agreement is valid except to the extent that it was superseded by Plaintiff’s acceptance of the 2019 Agreement.  

C. Authentication of 2019 Agreement

Plaintiff contends that Defendant failed to authenticate the 2019 Agreement properly.

Courts apply a three-step burden-shifting process to determine whether an agreement to arbitrate exists. Gamboa v. Northeast Community Clinic (2021) 72 Cal.App.5th 158, 164. “First, the moving party bears the burden of producing ‘prima facie evidence of a written agreement to arbitrate the controversy.’” Id. at 165 (quoting Rosenthal v. Great Western Fin. Securities Corp. (1996) 14 Cal.4th 394, 413.  The moving party can meet this initial burden by attaching a copy of the arbitration agreement purporting to bear the opposing party’s signature or setting forth the agreement’s provisions in the motion. Ibid.  “For this step, ‘it is not necessary to follow the normal procedures of document authentication.” Ibid. (quoting Condee v. Longwood Management Corp. (2001) 88 Cal.App.4th 215, 218).

“If the movant bears its initial burden, the burden shifts to the party opposing arbitration to identify a factual dispute as to the agreement’s existence—in this instance, by disputing the authenticity of their signatures. To bear this burden, the arbitration opponent must offer admissible evidence creating a factual dispute as to the authenticity of their signatures. The opponent need not prove that his or her purported signature is not authentic but must submit sufficient evidence to create a factual dispute and shift the burden back to the arbitration proponent, who retains the ultimate burden of proving, by a preponderance of the evidence, the authenticity of the signature.” Iyere v. Wise Auto Group (2023) 87 Cal.App.5th 747, 755,

Here, the Court finds that Defendant met its initial burden by providing a copy of the 2019 Agreement, which purportedly bears Plaintiff’s electronic signature. Wicker Decl., Ex. 2, Ex. 5. The burden then turns to Plaintiff to provide evidence disputing the signature's authenticity.  Plaintiff has offered no declaration or other evidence disputing that she signed the agreement.  In the absence of such evidence, Plaintiff has failed to meet her burden.  Accordingly, the Court accepts the validity of Plaintiff’s electronic signature on the 2019 Agreement on its face and need not address whether Defendant properly authenticated it. 

D. Inadequate Forum

Next, Plaintiff argues that the arbitration required by the 2019 Agreement is an inadequate forum for resolving her claims.   

An adequate arbitration agreement is one that “(1) provides for neutral arbitrators, (2) provides for more than minimal discovery, (3) requires a written award, (4) provides for all of the types of relief that would otherwise be available in court, and (5) does not require employees to pay either unreasonable costs or any arbitrators’ fees or expenses as a condition of access to the arbitration forum.”  Armendariz v. Foundation Health Psychcare Services, Inc. (2000) 24 Cal.4th 83, 102 (Armendariz) (citation omitted) (internal quotation marks omitted). “[W]hen an employer imposes mandatory arbitration as a condition of employment, the arbitration agreement or arbitration process cannot generally require the employee to bear any type of expense that the employee would not be required to bear if he or she were free to bring the action in court.” Id. at pp. 110-111. 

Plaintiff argues that the provision of the 2019 Agreement, which allows the arbitrator to award attorney’s fees and costs to the prevailing party at his discretion, renders the arbitration inadequate. Plaintiff contends that prevailing parties in FEHA actions are entitled to recover attorney’s fees and costs, and the provision granting the arbitrator discretion conflicts with Plaintiff’s rights under the statute. Therefore, Plaintiff argues the agreement violates the requirements that her costs do not exceed those she would have to pay in court and that all types of relief otherwise available in a non-arbitration forum be available.

Contrary to Plaintiff’s claim, attorney fees under FEHA are not mandatory but discretionary. Government Code section 12965, subdivision (c)(6) provides in relevant part, “In civil actions brought under this section, the court, in its discretion, may award to the prevailing party, including the department, reasonable attorney’s fees and costs…. (Emphasis added).

Similarly, the arbitration agreement provides, “the arbitrator may include reasonable attorneys’ fees, costs and expenses as part of the arbitration award to the prevailing party to the extent permitted by applicable law…. Wicker Decl., Ex. 2 at p. 5.

The Court concludes that this provision does not inflict upon Plaintiff either greater costs than those which would be incurred in court or deny her any form of relief available in a non-arbitration forum.

E. Unconscionability

Plaintiff further argues that the agreement is not enforceable because it is unconscionable. 

Like any other contract, arbitration agreements are subject to a defense of unconscionability. Armendariz, supra, 24 Cal.4th at p. 113. “The general principles of unconscionability are well established. A contract is unconscionable if one of the parties lacked a meaningful choice in deciding whether to agree and the contract contains terms that are unreasonably favorable to the other party. Unconscionability has both a procedural and a substantive element. The party resisting enforcement of an arbitration agreement has the burden to establish unconscionability.” Ramirez v. Charter Communications, Inc. (2024) 16 Cal.5th 478, 492 (citations omitted) (internal quotation marks omitted).

“[P]rocedural and substantive unconscionability must both be present in order for a court to exercise its discretion to refuse to enforce a contract or clause under the doctrine of unconscionability. But they need not be present in the same degree. Essentially a sliding scale is invoked which disregards the regularity of the procedural process of the contract formation, that creates the terms, in proportion to the greater harshness or unreasonableness of the substantive terms themselves. In other words, the more substantively oppressive the contract term, the less evidence of procedural unconscionability is required to come to the conclusion that the term is unenforceable, and vice versa.” Baltazar v. Forever 21, Inc. (2016) 62 Cal.4th 1237, 1243-44 (Baltazar) (cleaned up).

1. Procedural Unconscionability

Plaintiff argues that the agreement is procedurally unconscionable because it is a contract of adhesion and because Defendant did not provide Plaintiff with a copy of the arbitration rules.

A “contract of adhesion” is “a standardized contract, which, imposed and drafted by the party of superior bargaining strength, relegates to the subscribing party only the opportunity to adhere to the contract or reject it.” Armendariz, supra, 24 Cal.4th at 113 (quoting Neal v. State Farm Ins. Cos. (1961) 188 Cal. App. 2d 690, 694. “[C]ontracts of adhesion, although they are indispensable facts of modern life that are generally enforced, contain a degree of procedural unconscionability even without any notable surprises, and bear within them the clear danger of oppression and overreaching.” Baltazar, supra, 62 Cal.4th 1237, 1244 (citation omitted) (internal quotation marks omitted).

“[C]ourts will more closely scrutinize the substantive unconscionability of terms that were ‘artfully hidden’ by the simple expedient of incorporating them by reference rather than including them in or attaching them to the arbitration agreement. Baltazar, supra, 62 Cal.4th at p. 1246. In Harper v. Ultimo (2003) 113 Cal.App.4th 1402, 1405-06, the court found an arbitration agreement procedurally unconscionable where it did not include a copy of the arbitration rules but instead incorporated them by reference, and the rules limited the damages and remedies available to dissatisfied customers. However, failure to provide a copy of the arbitration rules supports a finding of procedural unconscionability only when the substantive unconscionability claim relates to those rules. Balazar 62 Cal.4th at p. 1246. Where the challenge concerns only matters that were clearly delineated in the agreement the employee signed, the employer’s failure to attach the arbitration rules does not affect the level of procedural unconscionability. Ibid.

Here, the agreement was a contract of adhesion. The contract was offered on a take-it-or-leave-it basis, and Plaintiff had no ability to negotiate the terms. See Wicker Decl., Ex. 3, Ex. 4. Therefore, there is at least a low level of procedural unconscionability.

While Plaintiff argues that there is a heightened level of procedural unconscionability because Defendant did not provide a copy of the arbitration rules with the agreement, this argument is without merit because Plaintiff does not argue that those rules are substantively unconscionable.

Accordingly, the Court finds a low level of procedural unconscionability typical of mandatory employment arbitration agreements.

2. Substantive Unconscionability

Substantive unconscionability focuses on the actual terms of the agreement and evaluates whether they create overly harsh or one-sided results as to shock the conscience. Suh v. Superior Court (2010) 181 Cal.App.4th 1504, 1515.

“When, as here, there is no other indication of oppression or surprise, the degree of procedural unconscionability of an adhesion agreement is low, and the agreement will be enforceable unless the degree of substantive unconscionability is high.” Serpa v. California Surety Investigations, Inc. (2013) 215 Cal.App.4th 695, 704 (citation omitted) (internal quotation marks omitted).

a. Attorney’s Fees

First, Plaintiff repeats her earlier argument regarding the arbitrator’s discretion to award attorney’s fees. For the reasons above, this argument fails to establish any substantive unconscionability.

b. Class Action/PAGA

Second, Plaintiff argues that the agreement is substantively unconscionable because it requires the parties to waive their rights to participate in class actions or PAGA claims.

“[A] state’s refusal to enforce [a class action] waiver on grounds of public policy or unconscionability is preempted by the FAA.” Iskanian v. CLS Transportation Los Angeles, LLC (2014) 59 Cal.4th 348, 360 (Iskanian) (overruled on other grounds in Viking River Cruises, Inc. v. Moriana (2022) 596 U.S. 639, 662 (Viking)).

An employee’s right to bring a PAGA action “is unwaivable.” Id. at p. 383. The FAA does not preempt the state’s rule against wholesale waiver of PAGA claims. Viking, supra, 596 U.S. at p. 662. However, the FAA preempts California case law, preventing the separation of “individual” and “non-individual” PAGA claims. Id. An arbitration agreement is enforceable against individual claims but not against non-individual representational claims. Id. The employee retains standing to bring representational claims, which may be stayed pending the outcome of the arbitration. Adolph v. Uber Technologies, Inc. (2023) 14 Cal.5th 1104, 1125.

While limiting Plaintiff’s ability to bring a class action may be unconscionable, the FAA preempts this Court’s ability to deny the motion to compel arbitration on that basis. Iskanian, supra, 59 Cal.4th at p. 360.

Because Plaintiff does not allege any representational PAGA claims, the Court need not decide if the agreement's language extends to such claims.  However, to the extent it does, that provision is unenforceable. 

 

c. Severability

Finally, Plaintiff objects to the broad severability provision in the agreement because she argues it calls for severability even in cases where the agreement is permeated with unconscionability. 

Civil Code §1670.5 requires that “an arbitration agreement permeated by unconscionability, or one that contains unconscionable aspects that cannot be cured by severance, restriction, or duly authorized reformation, should not be enforced.” Armendariz, supra, 24 Cal.4th at p. 126.

Here, the agreement includes a severance clause stating in relevant part, “the terms of this Arbitration Agreement are severable, and the invalidity or unenforceability of any provision will not affect the application of any other provision.” Wicker Decl. Ex. 2 at p. 7

This severability clause does not contradict the case law concerning severability because if the Court finds that the agreement is permeated with procedural unconscionability, it does not sever any provisions but deems the entire agreement unenforceable. The inclusion of the severability clause serves only as an expression of the party's intent that where individual portions of the agreement are unenforceable, the contract as a whole should still be enforced.  But when an arbitration agreement is permeated with unconscionability, no provisions are severed, and the contract as a whole is unenforceable.

 

Accordingly, the Court finds no substantive unconscionability (and only a very low level of procedural unconscionability), and the motion to compel arbitration is granted. 

 

CONCLUSION

Defendant’s Motion to Compel Arbitration is granted.