Judge: Armen Tamzarian, Case: 22STCV15941, Date: 2024-03-28 Tentative Ruling

Please notify Department 52 via email at smcdept52@lacourt.org and indicate that the parties are submitting on the tentative ruling. Please provide the attorney's name and represented party. Please notify the opposing side via email if submitting on the Court's tentative ruling.




Case Number: 22STCV15941    Hearing Date: March 28, 2024    Dept: 52

Plaintiff Sara Simms’s Motion for Determination That Predispute Arbitration Agreement is Invalid and Unenforceable as to the Sexual Harassment Dispute

Plaintiff Sara Simms moves for an order that the parties’ arbitration agreement is invalid as to her claims for sexual harassment. 

The Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act (EFAA) provides: “[A]t the election of the person alleging conduct constituting a sexual harassment dispute or sexual assault dispute, … no predispute arbitration agreement … shall be valid or enforceable with respect to a case which is filed under Federal, Tribal, or State law and relates to the sexual assault dispute or the sexual harassment dispute.”  (9 U.S.C. § 402(a).) 

Stay of Action

            Defendants Epione Medical Corporation, Epione Beverly Hills, Inc., Beverly Hills Plastic Surgery Associates, and Simon Ourian argue this motion is procedurally defective because the court stayed the action.  “[A]fter granting a petition to compel arbitration and staying a lawsuit, the scope of jurisdiction that a trial court retains is extremely narrow.”  (MKJA, Inc. v. 123 Fit Franchising, LLC (2011) 191 Cal.App.4th 643, 658.)  “[T]he purpose of” staying the action under the California Arbitration Act “is to protect the jurisdiction of the arbitrator by preserving the status quo until the arbitration is resolved.”  (Id. at p. 660.) 

The court has jurisdiction to consider this motion.  The EFAA provides, “The applicability of this chapter to an agreement to arbitrate and the validity and enforceability of an agreement to which this chapter applies shall be determined by a court, rather than an arbitrator, irrespective of whether the party resisting arbitration challenges the arbitration agreement specifically or in conjunction with other terms of the contract containing such agreement, and irrespective of whether the agreement purports to delegate such determinations to an arbitrator.”  (9 U.S.C. § 402(b).)  Congress thus expressly required that a court, not an arbitrator, must determine whether the EFAA applies to this case.  Doing so may mean the arbitrator has no jurisdiction over part of the proceeding.  Declining to decide the issue because the case was stayed pending arbitration would undermine the purpose of the EFAA and the purpose of arbitration as an efficient way to resolve disputes.

Assuming lifting the stay is required, the court hereby lifts the stay of this action for the limited purpose of deciding this motion. 

Waiver

            Defendants argue plaintiff waived the right to invalidate the arbitration agreement under the EFAA.  Defendants rely on authority about waiving the right to enforce an arbitration agreement.  Neither party cites authority on waiving the right to invalidate an arbitration agreement.  Generally, “[w]aiver is the intentional relinquishment of a known right after full knowledge of the facts.”  (DRG/Beverly Hills, Ltd. v. Chopstix Dim Sum Cafe & Takeout III, Ltd. (1994) 30 Cal.App.4th 54, 59.)  The party asserting waiver bears the burden of proving it applies.  (Insurance Co. of the West v. Haralambos Beverage Co. (1987) 195 Cal.App.3d 1308, 1320.)

            Defendants do not show that plaintiff intentionally relinquished a known right to invoke the EFAA.  The court granted defendants’ motion to compel arbitration on January 27, 2023.  On January 29, 2024, the Court of Appeal issued a new decision with a different interpretation of when a dispute arises under the EFAA.  (Kader v. Southern California Medical Center, Inc. (2024) 99 Cal.App.5th 214 (Kader).)  Prior authority generally interpreted the EFAA to apply if the cause of action accrued after the law took effect in March 2022.  (See Murrey v. Superior Court (2023) 87 Cal.App.5th 1223, 1235 (Murrey); Walters v. Starbucks Corp. (S.D.N.Y. 2022) 623 F.Supp.3d 333, 337; Newcombe-Dierl v. Amgen (C.D. Cal., May 26, 2022, No. CV222155DMGMRWX) 2022 WL 3012211, at *5.)  Plaintiff’s causes of action accrued in 2020.  But, as the court will discuss below, her “sexual harassment dispute” may have arisen after that date.  She therefore did not know she had any right to invoke the EFAA until after the Court of Appeal decided Kader. 

Reconsideration

            Defendants argue this is an improper motion for reconsideration of the court’s order compelling arbitration.  Assuming this constitutes a motion for reconsideration, the Kader decision justifies reconsideration.  “If a court at any time determines that there has been a change of law that warrants it to reconsider a prior order it entered, it may do so on its own motion and enter a different order.”  (CCP § 1008(c).)  If doing so were necessary, the court would find Kader is a change of law that warrants the court to reconsider its order compelling arbitration.

Sexual Harassment Dispute

            Defendants argue this action does not constitute a sexual harassment dispute because plaintiff only alleges harassment based on pregnancy.  The EFAA provides, “The term ‘sexual harassment dispute’ means a dispute relating to conduct that is alleged to constitute sexual harassment under applicable Federal, Tribal, or State law.”  (9 U.S.C. § 401(4).)  The applicable State law, the Fair Employment and Housing Act (FEHA), defines “sex” to include “[p]regnancy or medical conditions related to pregnancy.”  (Gov. Code, § 12926(r)(1)(A).)  FEHA provides that it is an unlawful for an employer to harass an employee “because of” their status in any protected class, including “sex.”  (Gov. Code, § 12940(j)(1).)  FEHA does not provide any separate definition of “sexual harassment.”  Under applicable State law, pregnancy harassment is sexual harassment.  The EFAA applies to this dispute. 

When the Sexual Harassment Dispute Arose

            The EFAA “does not apply retroactively.”  (Murrey, supra, 87 Cal.App.5th at p. 1230.)  It only applies if the “sexual harassment dispute” arose after the law took effect on March 3, 2022.  “[T]he date that a dispute has arisen for purposes of the Act is a fact-specific inquiry in each case, but a dispute does not arise solely from the alleged sexual conduct.  A dispute arises when one party asserts a right, claim, or demand, and the other side expresses disagreement or takes an adversarial posture.”  (Kader, supra, 99 Cal.App.5th at p. 222.)  “Unlike a claim, however, a dispute does not arise simply because the plaintiff suffers an injury; it additionally requires a disagreement or controversy.”  (Id. at p. 223.) 

Plaintiff shows the sexual harassment dispute arose after March 3, 2022.  She filed her administrative complaint with the former Department of Fair Employment and Housing (DFEH) on April 22, 2022.  (Gutierrez Decl., ¶ 4, Ex. B.)  Nothing in the record shows any claim of sexual harassment or disagreement about such a claim before she filed the DFEH complaint.  To the contrary, defendants’ sworn discovery responses state, “Claimant did not make any complaint against Respondent during her employment.”  (Gutierrez Decl., Ex. E, p. 12, response to interrogatory No. 207.1(d).)   

Defendants rely on the following allegation in plaintiff’s complaint: “On March 10, 2020, OURIAN met with Plaintiff and told her he would not be changing his decision on the bonus issue.  OURIAN further stated that it was non-negotiable that she begin using a timeclock to record her hours.”  (Comp., ¶ 43; FAC, ¶ 43.)  Assuming this allegation establishes a disagreement or dispute, it is not a “sexual harassment dispute.”  It is a sex discrimination dispute. 

Discrimination concerns unequal terms and conditions of employment, while “harassment focuses on situations in which the social environment of the workplace becomes intolerable because the harassment (whether verbal, physical, or visual) communicates an offensive message to the harassed employee.”  (Roby v. McKesson Corp. (2009) 47 Cal.4th 686, 706.)  Allegedly not paying plaintiff a bonus and requiring her to record her hours are terms and conditions of employment, not offensive messages arising from the workplace’s social environment.  Defendants do not show that any disagreement or adversarial posture about the alleged sexual harassment arose before plaintiff filed her DFEH complaint on April 22, 2022.       

Disposition

Plaintiff Sara Simms’s motion for determination that predispute arbitration agreement is invalid and unenforceable as to the sexual harassment dispute is granted.  Under 9 U.S.C. § 402(b), the court hereby finds that the parties’ predispute arbitration agreement is invalid and unenforceable as to plaintiff’s sixth cause of action for “FEHA Hostile Work Environment” and her seventh cause of action for “FEHA Harassment.”