Judge: Douglas W. Stern, Case: 22STCV12372, Date: 2022-09-16 Tentative Ruling

Case Number: 22STCV12372    Hearing Date: September 16, 2022    Dept: 52

Tentative Ruling:

          Defendant WDW Joint Venture dba Downey Community Health Center’s Motion to Compel Arbitration and Stay Proceedings

Defendant WDW Joint Venture moves to compel arbitration and stay this case.  Plaintiff Jessica Gomez opposes the motion on two grounds.

Evidentiary Objections      

          Plaintiff makes three objections to the declaration of Elsa Custodio.  All three objections are overruled. 

Existence of Agreement

First, plaintiff argues she never agreed to arbitration because she never received the Employment Dispute Resolution booklet.  Even if plaintiff never received the booklet, she agreed to it by communicating her consent to defendant.  Contract formation is governed by objective manifestations, not the subjective intent of any individual involved.  The test is what the outward manifestations of consent would lead a reasonable person to believe.  (Allen v. Smith (2002) 94 Cal.App.4th 1270, 1277, internal quotes and alterations omitted.)  “[O]rdinarily one who signs an instrument which on its face is a contract is deemed to assent to all its terms.” (Marin Storage & Trucking, Inc. v. Benco Contracting and Engineering, Inc. (2001) 89 Cal.App.4th 1042, 1049–1050; see Williston on Contracts § 4:19 (4th ed. 2020) [“what is essential is not assent, but rather what the person to whom a manifestation is made is justified as regarding as assent”].)

Plaintiff signed a document titled, “Employment Dispute Resolution Program Acknowledgement.”  (Custodio Decl., Ex. 1.)  It states, “I acknowledge that I have received my copy of the Employee Dispute Resolution (EDR) Program booklet. … My signature below acknowledges that: * It is my responsibility to familiarize myself with its contents and have had the opportunity to ask questions about its contents.  If I have further questions, I will ask my Supervisor.  * I understand I am bound to use the EDR Program to resolve my employment related disputes as described within the booklet.”  (Ibid.)

Regardless of whether plaintiff received the booklet or “mistakenly” signed the acknowledgement, she signed it.  Doing so is the quintessential outward manifestation of consent.  Signing it would lead a reasonable person to believe she agreed to its terms.  The parties therefore entered this arbitration agreement.

Unconscionability

Second, plaintiff argues the agreement is unconscionable and therefore unenforceable.  Unconscionability requires both procedural and substantive unconscionability using a sliding scale.  (Serafin v. Balco Properties Ltd., LLC (2015) 235 Cal.App.4th 165, 185.)  The court finds the agreement is not enforceable because it has moderate procedural unconscionability and high substantive unconscionability. 

1. Procedural Unconscionability

Procedural unconscionability focuses on “‘oppression’ or ‘surprise’ due to unequal bargaining power.” (Armendariz v. Foundation Health Psychcare Services, Inc. (2000) 24 Cal.4th 83, 114 (Armendariz).)  “Procedural unconscionability occurs when the stronger party drafts the contract and presents it to the weaker party on a ‘take it or leave it basis.’ ”  (Trivedi v. Curexo Technology Corp. (2010) 189 Cal.App.4th 387, 393, disapproved of on other grounds by Baltazar v. Forever 21, Inc. (2016) 62 Cal.4th 1237.)

The arbitration agreement has moderate procedural unconscionability.  The parties’ unequal bargaining power renders it oppressive.  Signing the EDR acknowledgement is part of defendant’s standard onboarding process.  (Custodio Decl., ¶¶ 3, 5.)  “During new hire orientation in 2019, the new hires” received defendant’s “employment forms and policies, including the EDR Booklet and acknowledgment form, to review and complete.”  (Id., ¶ 5.)  Plaintiff states, “[A]s part of my onboarding, I was required to review and sign a multitude of paperwork” (Gomez Decl., ¶ 1), including the EDR acknowledgment (Id., ¶ 2). 

The EDR Booklet also states, “Your decision to accept employment or to continue employment with the Company constitutes your agreement to be bound by the EDR Program.”  (Custodio Decl., Ex. 1, p. 1.)  The arbitration agreement is a classic take it or leave it adhesion contract imposed by the employer on the employee as a condition of employment.

2. Substantive Unconscionability

The agreement is highly substantively unconscionable because it is not mutual.  “In assessing substantive unconscionability, the paramount consideration is mutuality.”  (Pinela v. Neiman Marcus Group, Inc. (2015) 238 Cal.App.4th 227, 241, internal quotations and citations omitted.) 

The Supreme Court of California has stated, “Given the lack of choice and the potential disadvantages that even a fair arbitration system can harbor for employees, we must be particularly attuned to claims that employers with superior bargaining power have imposed one-sided, substantively unconscionable terms as part of an arbitration agreement.”  (Armendariz, supra, 24 Cal.4th at p. 115.)  “Given the disadvantages that may exist for plaintiffs arbitrating disputes, it is unfairly one-sided for an employer with superior bargaining power to impose arbitration on the employee as plaintiff but not to accept such limitations when it seeks to prosecute a claim against the employee, without at least some reasonable justification for such one-sidedness based on ‘business realities.’” (Id. at p. 117.)

The agreement is one-sided because it only applies to disputes typically brought by employees.  “Courts repeatedly have found an employer-imposed arbitration agreement to be substantively unconscionable when it requires the employee to arbitrate the claims he or she is mostly likely to bring, but allows the employer to go to court to pursue the claims it is most likely to bring.”  (Carbajal v. CWPSC, Inc. (2016) 245 Cal.App.4th 227, 248.)    

Here, the EDR booklet provides that both parties “are bound to use the EDR Program as the only means of resolving employment related disputes and to forego any right either may have to a jury trial on issues covered by the EDR Program.”  (Custodio Decl., Ex. 1, p. 1.)  Though this agreement purports to be mutual, the “issues covered by the EDR Program” are limited to claims brought by employees.

The agreement provides, “Disputes covered under the EDR program pertain to claims such as discipline, discrimination, fair treatment, harassment, termination and other legally protected rights.  Disputes not covered under the EDR Program relate to workers’ compensation, unemployment benefits, health, welfare and retirement benefits and claims by the Company for injunctive relief to protect trade secrets and confidential information.”  (Custodio Decl., Ex. 1, p. 3.)  Though the agreement excludes some forms of employee claims, most of them are not arbitrable as a matter of law.  (Mercuro v. Superior Court (2002) 96 Cal.App.4th 167, 176 (Mercuro).) 

The agreement is equivalent to others that have been held substantively unconscionable.  In Mercuro, “[t]he arbitration agreement specifically cover[ed] claims for breach of express or implied contracts or covenants, tort claims, claims of discrimination based on race, sex, age or disability, and claims for violation of any federal, state or other governmental constitution, statute, ordinance, regulation or public policy.”  (Id. at pp. 175-176.)  But it “specifically exclude[d] ‘claims for injunctive and/or other equitable relief for intellectual property violations, unfair competition and/or the use and/or unauthorized disclosure of trade secrets or confidential information…’ ”  (Id. at p. 176.)

Similarly, in Ramirez v. Charter Communications, Inc. (2022) 75 Cal.App.5th 365 (Ramirez), the court held an agreement was not mutual where it “specifically cover[ed] claims ‘related to pre-employment, employment, employment termination or post-employment-related claims, whether the claims are dominated as tort, contract, common law, or statutory claims,’ including … whistleblowers; unlawful termination; … violations of wage and hour laws; [and] unlawful discrimination and harassment,” among others.  (Id. at p. 383.)  “On the other hand, the arbitration agreement specifically exclude[d] ‘claims for injunctive or other equitable relief related to unfair competition and the taking, use or unauthorized disclosure of trade secrets or confidential information.’  The agreement further excludes claims: arising under separate or severance agreements or non-compete agreements; for theft or embezzlement or any other criminal conduct; and over the validity of any party’s intellectual property rights.”  (Ibid.)

Here, the parties’ agreement specifically applies only to claims normally brought by employees.  Its only reference to any claim normally brought by employers is to exclude “claims by the Company for injunctive relief to protect trade secrets and confidential information.”  (Custodio Decl., Ex. 1, p. 3.)

Defendant offers no business justification for the agreement’s lack of mutuality.  The agreement is therefore highly substantively unconscionable. 

Severability

Severance cannot fix the agreement’s lack of mutuality.  “[I]n the case of the agreement’s lack of mutuality, such permeation is indicated by the fact that there is no single provision a court can strike or restrict in order to remove the unconscionable taint from the agreement.  Rather, the court would have to, in effect, reform the contract, not through severance or restriction, but by augmenting it with additional terms.”  (Armendariz, supra, 24 Cal.4th at pp. 124-125.)

Here, there is no single term or provision that could be stricken.  Making the agreement enforceable would require augmenting it with additional terms—which the court cannot do.

Disposition

          The motion is denied.