Judge: Ashfaq G. Chowdhury, Case: 23GDCV01005, Date: 2024-03-22 Tentative Ruling

Case Number: 23GDCV01005    Hearing Date: March 22, 2024    Dept: E

Hearing Date: 03/22/2024 – 8:30am
Case No: 23GDCV01005
Trial Date: UNSET
Case Name: JESSE FLORES, individually and on behalf of all other Aggrieved Employees; v. MANPOWER US INC., MANPOWERGROUP US INC., ZARA USA, INC., and DOES 1-50

TENTATIVE RULING ON DEFENDANT’S MOTION TO COMPEL ARBITRATION

 

RELIEF REQUESTED
“Defendants, Manpower US Inc. and ManpowerGroup US Inc. (“Manpower Defendants”) will and hereby do move the Court for an Order (i) compelling Plaintiff Jesse Flores (“Plaintiff”) to arbitrate her claims on an individual basis, including her individual claims brought under the Private Attorneys General Act (“PAGA”), pursuant to the terms of a valid and enforceable arbitration agreement; (ii) staying Plaintiff’s non-individual PAGA claims; and (iii) staying proceedings pending completion of the individual arbitration.

Manpower Defendants bring this Motion because the Court lacks subject matter jurisdiction over Plaintiff’s individual claims due to a binding, written arbitration agreement governing the dispute. Under the agreement, Plaintiff agreed to arbitrate all claims on an individual basis.1 Under the Federal Arbitration Act and the California Arbitration Act, the Court must order arbitration consistent with the agreement and stay Plaintiff’s non-individual PAGA claims pending individual arbitration.

[Footnote 1 states, “By its terms and California jurisprudence, the agreement Plaintiff executed with applies to all Defendants, including Zara USA, Inc.”]

Manpower Defendants base this Motion upon this Notice of Motion and Motion, the accompanying Memorandum of Points and Authorities, the Declaration of Malinda Searle, the accompanying exhibits, all papers and pleadings filed in this action, and any other evidence and argument as presented in connection with the hearing on this Motion.”

 

PROCEDURAL

Proof of Service Timely Filed (CRC Rule 3.1300): Ok
16/21 Court Days Lapsed (CCP 1005(b)): Ok
Proper Address: Ok

Moving Party: Defendants, Manpower US Inc. and ManpowerGroup US Inc. (Manpower Defendants or Movants)

 

Defendant, Zara USA, Inc. filed a notice of joinder to Manpower Defendants’ Motion to Compel Arbitration.

 

Responding Party: Plaintiff, Jesse Flores

Moving Papers (Movants): Notice; Memorandum; Searle Declaration; Proposed Order; Proof of Service;

 

Moving Papers: Notice of Joinder by Zara

 

Opposition Papers: Opposition

 

Reply Papers (Movants) : Reply; Request for Judicial Notice

 

Reply: Reply by Zara

 

 

BACKGROUND

Manpower Defendants move to compel arbitration of Plaintiff’s individual PAGA claims and stay her non-individual PAGA claims and any other proceedings.

LEGAL STANDARD – COMPEL ARBITRATION
CCP § 1281.2, governing orders to arbitrate controversies, provides: 

“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, unless it determines that: 

(a) The right to compel arbitration has been waived by the petitioner; or 

(b) Grounds exist for the rescission of the agreement.  

(c) A party to the arbitration agreement is also a party to a pending court action or special proceeding with a third party, arising out of the same transaction or series of related transactions and there is a possibility of conflicting rulings on a common issue of law or fact. For purposes of this section, a pending court action or special proceeding includes an action or proceeding initiated by the party refusing to arbitrate after the petition to compel arbitration has been filed, but on or before the date of the hearing on the petition. This subdivision shall not be applicable to an agreement to arbitrate disputes as to the professional negligence of a health care provider made pursuant to Section 1295....” 

 

(CCP § 1281.2(a)-(c).)

 

There is a strong public policy in favor of arbitration of disputes and any doubts concerning the scope of arbitrable disputes should be resolved in favor of arbitration. (Moncharsh v. Heily & Blase (1992) 3 Cal.4th 1, 9.) Arbitration agreements should be liberally interpreted, and arbitration should be ordered unless the agreement clearly does not apply to the dispute in question. (Vianna v. Doctors’ Management Co. (1994) 27 Cal.App.4th 1186, 1189.)    

The Court’s starting point is whether a valid agreement to arbitrate exists. (Cruise v. Kroger Co. (2015) 233 Cal.App.4th 390, 396.) In ruling on a motion to compel arbitration, the court must first determine whether the parties actually agreed to arbitrate the dispute, and general principles of California contract law help guide the court in making this determination. (Mendez v. Mid-Wilshire Health Care Center (2013) 220 Cal.App.4th 534, 541.) A petition to compel arbitration is a suit in equity to compel specific performance of a contract. (Frog Creek Partners, LLC. v. Vance Brown, Inc. (2012) 206 Cal.App.4th 515, 532.) 

Where a petition is opposed, the burden is on the party seeking to compel arbitration to establish the existence of a valid agreement to arbitrate. (Banner Entertainment, Inc. v. Superior Court (1998) 62 Cal.App.4th 348, 356.) The determination of arbitrability is a legal question subject to de novo review. An appellate court will uphold the trial court's resolution of disputed facts if supported by substantial evidence. (Nyulassy v. Lockheed Martin Corp. (2004) 120 Cal.App.4th 1267.) 

ANALYSIS
Preliminary Matter
Plaintiff argues that her Complaint alleges only a “representative” claim because it filed the Complaint as a Representative Plaintiff on behalf of all other Aggrieved Employees.

Plaintiff appears to be making this argument under the following theory: Since representative PAGA claims cannot be compelled to arbitration, and since Plaintiff’s only claim is a representative claim, there is no individual claim that can be compelled to arbitration.

The Court does not find this argument availing. The Complaint does in fact appear to be asserting both an individual and a representative claim.

First, Plaintiff’s Opposition contradicts its own argument. Opposition explicitly admits that “Plaintiff further seeks civil penalties on behalf of himself as a Representative Plaintiff and all other Aggrieved Employees.” (Oppo. p. 6.)

Second, the Complaint itself indicates Plaintiff is seeking relief for an individual and representative claim. The caption of the Complaint reads, “Jess Flores, individually and on behalf of all other Aggrieved Employees.” Although the Complaint indicates that Jesse Flores is referred to as “REPRESENTATIVE PLAINTIFF,” Plaintiff’s attempt to argue there is no individual claim seems as if it is trying to get around the fact that Plaintiff asserts an induvial claim based on a technical labeling.

As indicated in ¶63, “REPRESENTATIVE PLAINTIFF and the other hourly-paid or non-exempt employees, are “AGGRIEVED EMPLOYEES” within the meaning of California Labor Code section 2699(c) as they are all current or former employees of DEFENDANT, and one or more of the alleged violations was committed against them.” (Compl. ¶63.) Plaintiff distinguishes between herself the individual, and the other employees.

Plaintiff seems to misunderstand how the phrase “representative” and “individual” are used in the context of PAGA.

“To have PAGA standing, a plaintiff must be an “aggrieved employee” – that is, (1) “someone ‘who was employed by the alleged violator’” and (2) “ ‘against whom one or more of the alleged violations was committed.”” (Adolph v. Uber Technologies, Inc. (2023) 14 Cal.5th 1104, 1114 citing Kim v. Reins International California, Inc. (2020) 9 Cal.5th 73, 83, 84.)

In explaining the use of the word “representative” :

In the first sense, PAGA actions are “representative” in that they are brought by employees acting as representatives—that is, as agents or proxies—of the State. But PAGA claims are also called “representative” when they are predicated on code violations sustained by other employees. In the first sense, “ ‘every PAGA action is ... representative’ ” and “[t]here is no individual component to a PAGA action,” Kim, 9 Cal.5th at 87, 259 Cal.Rptr.3d 769, 259 Cal.Rptr.3d, 459 P.3d at 1131 (quoting Iskanian, 59 Cal.4th at 387, 173 Cal.Rptr.3d 289, 327 P.3d at 151), because every PAGA claim is asserted in a representative capacity. But when the word “representative” is used in the second way, it makes sense to distinguish “individual” PAGA claims, which are premised on Labor Code violations actually sustained by the plaintiff, from “representative” (or perhaps quasi-representative) PAGA claims arising out of events involving *649 other employees. For purposes of this opinion, we will use “individual PAGA claim” to refer to claims based on code violations suffered by the plaintiff. And we will endeavor to be clear about how we are using the term “representative.”

(Viking River Cruises, Inc. v. Moriana (2022) 596 U.S. 639, 648-649.)

In ¶63, Plaintiff alleges she is an aggrieved employee and that an alleged violation was committed against her, thus Plaintiff asserts an individual claim.

Agreement to Arbitrate
Where a petition is opposed, the burden is on the party seeking to compel arbitration to establish the existence of a valid agreement to arbitrate. (Banner Entertainment, Inc. v. Superior Court (1998) 62 Cal.App.4th 348, 356.) The determination of arbitrability is a legal question subject to de novo review. An appellate court will uphold the trial court's resolution of disputed facts if supported by substantial evidence. (Nyulassy v. Lockheed Martin Corp. (2004) 120 Cal.App.4th 1267.) 

Movants attach the agreement to arbitrate in Exhibit 1 of the Searle Declaration.

Plaintiff argues that Defendants failed to demonstrate that a valid arbitration agreement exists between all parties.

Plaintiff’s argument is based on the fact that ManpowerGroup US Inc. is the only defendant named in the agreement to arbitrate, and Manpower US Inc. and Zara USA, Inc. are not parties to the agreement to arbitrate.

Plaintiff’s argument is unavailing.

The Court does not find Defendants’ argument that all Defendants are all parties to the agreement based on the agency argument in Thomas v. Westlake (2012) 204 Cal.App.4th 604, 614-615. Notably, the Complaint didn’t technically allege agency in the same manner in Thomas.

However, Movants’ citation to Garcia v. Pexco, LLC (2017) 11 Cal.App.5th 782 is on point.

As stated in Garcia :

Courts recognize exceptions to the general rule which allow nonsignatories to compel arbitration of a dispute arising out of the scope of the agreement. (Suh v. Superior Court (2010) 181 Cal.App.4th 1504, 1513, 105 Cal.Rptr.3d 585.) One of the exceptions is equitable estoppel. (Ibid.) Under this exception, “a nonsignatory defendant may invoke an arbitration clause to compel a signatory plaintiff to arbitrate its claim when the causes of action against the nonsignatory are ‘intimately founded in and intertwined with’ the underlying contract obligations.” (Bouchersupra, 127 Cal.App.4th at p. 271, 25 Cal.Rptr.3d 440.) The doctrine applies where the claims are “ ‘ “based on the same facts and are inherently inseparable’ ” from the arbitrable claims against signatory defendants.” (Metalclad Corp. v. Ventana Environmental Organizational Partnership (2003) 109 Cal.App.4th 1705, 1713, 1 Cal.Rptr.3d 328.)

(Garcia v. Pexco, LLC (2017) 11 Cal.App.5th 782, 785-786.)

In Garcia, Select Staffing (Real Time) hired Garcia and assigned Garcia to work for Pexco. As part of the hiring process with Real Time, Garcia filled out an employment application which included an arbitration agreement between Garcia and Real Time. Pexco was not a signatory to the arbitration agreement.

When explaining why equitable estoppel applied, the court in Garcia explained:

Like Boucher and unlike DMS Services, all of Garcia's claims are intimately founded in and intertwined with his employment relationship with Real Time, which is governed by the employment agreement compelling arbitration. Garcia cannot avoid his obligation to arbitrate his causes of action arising out of his employment relationship by framing his claims as merely statutory. On these facts, it is inequitable for the arbitration about Garcia's assignment with Pexco to proceed with Real Time, while preventing Pexco from participating. This is because Garcia's claims against Pexco are rooted in his employment relationship with Real Time, and the governing arbitration agreement expressly includes statutory wage and hour claims. Garcia does not distinguish between Real Time and Pexco in any way. All of Garcia's claims are based on the same facts alleged against Real Time. Garcia cannot attempt to link Pexco to Real Time to hold it liable for alleged wage and hour claims, while at the same time arguing the arbitration provision only applies to Real Time and not Pexco. Garcia agreed to arbitrate his wage and hour claims against his employer, and Garcia alleges Pexco and Real Time were his joint employers. Because the arbitration agreement controls Garcia's employment, he is equitably estopped from refusing to arbitrate his claims with Pexco.

(Garcia v. Pexco, LLC (2017) 11 Cal.App.5th 782, 787-788.)

Plaintiff alleged in her Complaint:

7. The AGGRIEVED EMPLOYEES worked for all of the DEFENDANTS or for any of the DEFENDANTS as non-exempt, hourly-paid employees. Nothing in this Complaint should be interpreted as limiting the AGGRIEVED EMPLOYEES to non-exempt, hourly-paid employees who worked for all DEFENDANTS only.

8. The definition of “employer” for purposes of the California Labor Code includes irregular working arrangements, and was specifically drafted in order to prevent evasion and subterfuge of California’s labor laws. To that end, REPRESENTATIVE PLAINTIFF is informed and believes, and based thereon alleges, that DEFENDANTS, including any as of now unknown entities, must be classified as joint-employers for purposes of liability for civil penalties under the Private Attorneys General Act (“PAGA”). As such, DEFENDANTS are each liable for civil penalties for violation of the California Labor Code as to REPRESENTATIVE PLAINTIFF and the other AGGRIEVED EMPLOYEES.

(Compl. ¶¶7-8.)

Similar to Garcia, all Plaintiff’s claims are based on the same facts alleged against all parties. Further, Plaintiff makes no attempt to distinguish between any of the named Defendants.

Opposition’s citation to Hernandez v. Meridian Management Service, LLC is unavailing. That case is inapposite. In that case, non-signatory defendants were trying to compel Plaintiff to arbitration based on an arbitration agreement between Plaintiff and an entity that was not even a party to the case.

Based on equitable estoppel, Defendants have demonstrated that a valid arbitration agreement exists between all parties.

Unenforceable Waiver of Plaintiff’s Right to Bring a Representative PAGA Action
Plaintiff is correct to note that under Iskanian and Viking River Cruises that the agreement cannot waive representative claims under PAGA. However, the Court fails to see how this agreement waives representative claims under PAGA. Plaintiff points to section 1D of the Arbitration Agreement, but that portion simply states that they agree to arbitrate PAGA claims on an individual basis only. This language does not seem to waive representative PAGA claims.

Unconscionable
Plaintiff argues that the arbitration agreement is both procedurally and substantively unconscionable. The Court does not find this argument availing.

Stay
Defendants argue for the representative claims be stayed until further proceedings pending arbitration of Plaintiff’s individual PAGA claim.

Plaintiff argues the Court has discretion and can decline to stay the representative claims.

“Moreover, case law establishes that a stay of proceedings as to any inarbitrable claims is appropriate until arbitration of any arbitrable claims is concluded.” (McGill v. Citibank, N.A. (2017) 2 Cal.5th 945, 966.)

Here, the Court plans to stay the non-individual claims (representative claims) pending the resolution of the individual claim that is being submitted to arbitration.

TENTATIVE RULING
Defendants’ motion to compel Plaintiff, Jesse Flores, to arbitrate her individual claims brought under PAGA is GRANTED. The representative/non-individual PAGA claims are stayed pending proceedings pending completion of the individual arbitration.