Judge: Gail Killefer, Case: 22STCV14354, Date: 2023-02-01 Tentative Ruling

Case Number: 22STCV14354    Hearing Date: February 1, 2023    Dept: 37

HEARING DATE:                 February 1, 2023

CASE NUMBER:                  22STCV14354

CASE NAME:                        Jose Vazquez Bautista, et al. v. Nissan North America, Inc., et al.

MOVING PARTY:                Defendant, Nissan North America, Inc. (“NNA”)

OPPOSING PARTY:             Plaintiff, Jose Vazquez Bautista aka Jose Vazquez

TRIAL DATE:                        Not set.

PROOF OF SERVICE:          OK

                                                                                                                                                           

MOTION:                               Defendant’s Motion to Compel Arbitration  

OPPOSITION:                       January 19, 2023

REPLY:                                  January 25, 2023

                                                                                                                                                           

TENTATIVE:                         Defendant’s motion is granted. Plaintiff is ordered to arbitrate his claims against NNA. This action is stayed pending completion of arbitration or further order of the court. The court sets an order to show cause re status of the arbitration for January 24, 2024, at 8:30 a.m. in Department 37. NNA is to give notice.

                                                                                                                                                           

Background

This is a lemon law action arising in connection with the purchase by Jose Vazquez Bautista aka Jose Vazquez (“Plaintiff”) of a 2021 Nissan Sentra on January 2, 2021 (the “Vehicle”) from Defendant LAD-N, LLC, dba “Lithia Nissan of Downtown LA” (“Dealer Defendant”).  Plaintiff alleges that Defendant Nissan North America, Inc. (“NNA”), which manufactured the Vehicle, provided Plaintiff various warranties in connection with the Vehicle in which Defendants undertook to preserve or maintain the performance of the Vehicle and to repair the Vehicle in the event of any defects during the warranty period. Plaintiff alleges that the Vehicle developed numerous defects during the warranty period, namely an emergency braking defect. Further, Plaintiff alleges that the Defendants failed to repair defects to the Vehicle when it was presented to Defendants and their authorized representatives for repair.

Plaintiff’s Complaint alleges the following causes of action: (1)  violation of the Song-Beverly Act—breach of express warranty against NNA, (2) fraudulent inducement—intentional misrepresentation against NNA (3) fraudulent inducement—concealment against NNA, and (4) negligent repair—Dealer Defendant.

NNA now moves to compel arbitration and for a stay of this action pending completion or arbitration. Plaintiff opposes the motion.

Request for Judicial Notice

NNA requests judicial notice of the following in support of its motion:

1.      Plaintiff’s Complaint, filed in this matter. (Exhibit 1).

2.      The Notice of Entry of Dismissal filed by Plaintiffs Dina C. Felisilda and Pastor O. Felisilda on February 11, 2016 in the matter Dina C. Felisilda, et al, v. FCA US LLC, et al., Sacramento Superior Court Case No. 34-2015-00183668. (Exhibit 2).

3.      NNA’s Answer to Plaintiff’s Complaint, filed in this matter. (Exhibit 3).

NNA’s requests are granted. The existence and legal significance of this document are proper matters for judicial notice. (Evidence Code § 452 (d), (h).) However, the court may not take judicial notice of the truth of the contents of the documents.  (Herrera v. Deutsche Bank National Trust Co. (2011) 196 Cal.App.4th 1366, 1375.)  Documents are only judicially noticeable to show their existence and what orders were made.  The truth of the facts and findings within the documents are not judicially noticeable.  (Lockley v. Law Office of Cantrell, Green, Pekich, Cruz & McCort (2001) 91 Cal.App.4th 875, 885.)

 

Evidentiary Objections

Plaintiff’s Objections to Declaration of Jason M. Richardson

 

Objection 1-3: overruled.

 

Discussion

I.                   Legal Standard

 

“California law reflects a strong public policy in favor of arbitration as a relatively quick and inexpensive method for resolving disputes.  To further that policy, Code of Civil Procedure, section 1281.2 requires a trial court to enforce a written arbitration agreement unless one of three limited exceptions applies.  Those statutory exceptions arise where (1) a party waives the right to arbitration; (2) grounds exist for revoking the arbitration agreement; and (3) pending litigation with a third party creates the possibility of conflicting rulings on common factual or legal issues.”  (CCP § 1281.2; Acquire II, Ltd. v. Colton Real Estate Group (2013) 213 Cal.App.4th 959, 967.)  Similarly, public policy under federal law favors arbitration and the fundamental principle that arbitration is a matter of contract and that courts must place arbitration agreements on an equal footing with other contracts and enforce them according to their terms.  (AT&T Mobility LLC v. Concepcion (2011) 563 U.S. 333, 339.)

In deciding a motion or petition to compel arbitration, trial courts must first decide whether an enforceable arbitration agreement exists between the parties and then determine whether the claims are covered within the scope of the agreement.  (Omar v. Ralphs Grocery Co. (2004) 118 Cal.App.4th 955, 961.)  The opposing party has the burden to establish any defense to enforcement.  (Gatton v. T-Mobile USA, Inc. (2007) 152 Cal.App.4th 571, 579 [“The petitioner ... bears the burden of proving the existence of a valid arbitration agreement and the opposing party, plaintiff here, bears the burden of proving any fact necessary to its defense.”].)

II.                Existence of an Arbitration Agreement

 

A motion to compel arbitration or stay proceedings must state verbatim the provisions providing for arbitration or must have a copy of them attached.  (Cal. Rules of Court, rule 3.1330.)

A party may demonstrate express acceptance of the arbitration agreement in order to be bound (e.g., Mago v. Shearson Lehman Hutton Inc. (9th Cir. 1992) 956 F.2d 932 [agreement to arbitrate included in job application]; Nghiem v. NEC Electronic, Inc. (9th Cir. 1994) 25 F.3d 1437 [agreement to arbitrate included in handbook executed by employee]; Lagatree v. Luce, Forward, Hamilton & Scripps (1999) 74 Cal. App. 4th 1105 [employer may terminate employee who refuses to sign agreement to arbitrate]) or implied-in-fact in fact acceptance (Asmus v. Pacific Bell (2000) 23 Cal. 4th 1, 11 [implied acceptance of changed rules regarding job security]; DiGiacinto v. Ameriko-Omserv Corp. (1997) 59 Cal. App. 4th 629, 635 [implied acceptance of changed compensation rules]).  (Craig v. Brown & Root (2000) 84 Cal.App.4th 416, 420 (Craig).) 

“A signed agreement is not necessary, however, and a party’s acceptance [of an agreement to arbitrate] may be implied in fact….”  (Pinnacle Museum Tower Ass’n v. Pinnacle Market Dev. (US), LLC (2012) 55 Cal.4th 223, 23 (Pinnacle), 6.)  “An arbitration clause within a contract may be binding on a party even if the party never actually read the clause.”  (Ibid.)

NNA contends that Plaintiff must be ordered to arbitrate his claims because the Arbitration Agreement found in the Retail Installment Sales Contract (the “Agreement”) Plaintiff executed at the time they purchased the Vehicle requires it. (Motion, 4-13; Declaration of Jason M. Richardson (“Richardson Decl.”), Exh. 1.) The Agreement provides in pertinent part as follows:

ARBITRATION PROVISION:

PLEASE REVIEW- IMPORTANT – AFFECTS YOUR LEGAL RIGHTS

1.      EITHER YOU OR WE MAY CHOOSE TO HAVE ANY DISPUTE BETWEEN US DECIDED BY ARBITRATION OR BY JURY TRIAL.

2.      IF A DISPUTE IS ARBITRATED, YOU WILL GIVE UP YOUR RIGHT TO PARTICIPATE AS A CLASS REPRESENTATIVE OR CLASS MEMBER ON ANY CLASS CLAIM YOU MAY HAVE AGAINST US INCLUDING ANY RIGHT TO CLASS ARBITRATION OR ANY CONSOLIDATION OF INDIVIDUAL ARBITRATIONS.

3.      DISCOVERY AND RIGHTS TO APPEAL IN ARBITRATION ARE GENERALLY MORE LIMITED THAN IN A LAWSUIT, AND OTHER RIGHTS THAT YOU AND WE WOULD HAVE IN COURT MAY NOT BE AVAILABLE IN ARBITRATION.

Any claim or dispute, whether in contract, tort, statute or otherwise (including the interpretation and scope of this Arbitration Provision and the arbitrability of the claim or dispute) between you and us or our employees, agents, successors or assigns, which arise out of or relate to  your credit application, purchase or condition of this vehicle, this contract or any resulting transaction or relationship (including any such relationship with third parties who do not sign this contract) shall, at your or our election, be resolved by neutral, binding arbitration and not by a court action. If federal law provides that a claim or dispute is not subject to binding arbitration, this Arbitration Provision shall not apply to any such claim or dispute. Any claim or dispute is to be arbitrated by a single arbitrator on an individual basis and not as a class action. You expressly waive any right you may have to arbitrate a class action. You may choose the American Arbitration Association…or any other organization to conduct arbitration subject to our approval. You may get a copy of the rules of an arbitration organization by contacting the organization or visiting its website.

Arbitrators shall be attorneys or retired judges and shall be selected pursuant to the applicable rules. The arbitrator shall apply substantive law and the applicable statute of limitations. The arbitration hearing shall be conducted in the federal district in which you reside unless the Seller-Creditor is a party to the claim or dispute, in which case the hearing will be held in the federal district where this contract was executed. We will pay your filing, administration, service or case management fee and your arbitrator and hearing fee and any arbitration appeal fees you incur all up to a maximum of $5000, unless the law or the rules of the chosen arbitration organization require us to pay more. The amount we pay may be reimbursed in whole or in part by decision of the arbitrator if the arbitrator finds that any of your claims is frivolous under applicable law. Each party shall be responsible or its own attorney, expert and other fees, unless awarded by the arbitrator under applicable law. ... Any arbitration under this Arbitration Provision shall be governed by the Federal Arbitration Act (9 U.S.C. § 1, et seq.) and not by any state law concerning arbitration. ...

You and we retain the right to seek remedies in small claims court for disputes or claims within the court’s jurisdiction, unless such action is transferred, removed or appealed to a different court. Neither you nor we waive the right to arbitrate by using self-help remedies, such as repossession, or by filing an action to recover to vehicle, to recover a deficiency balance, or for individual injunctive relief. Any court having jurisdiction may enter judgment on the arbitrator’s award. This Arbitration Provision shall survive any termination, payoff, or transfer of this contract. ...

(Richardson Decl., Exh. 1.)(emphasis added)

Additionally, NNA contends that notwithstanding its status as a non-signatory to the Agreement, NNA may still compel arbitration because claims against it are related to the condition of the Vehicle, that the Agreement is valid under the FAA, and was valid as agreed to between the parties. (Motion, 4-13.) NNA alternatively contends that it has standing to compel arbitration because it is an intended third-party beneficiary of the Agreement, as NNA is the manufacturer of the Vehicle. (Motion, 12-13.) Defendants cite to Felisilda v. FCA US LLC, (2020) 53 Cal.App. 5th 486 (Felisilda) for this argument.

Felisilda arose in connection with the sale of a used Dodge Grand Caravan that Plaintiffs purchased from a dealership and manufactured by defendant, FCA US, LLC. (“FCA”) (Id. at 489.) Plaintiffs brought an action against the dealership and FCA after the vehicle began exhibiting problems. (Id.) The dealership moved to compel arbitration relying on the retail installment sales contract signed by Plaintiffs, and the trial court ordered Plaintiffs to arbitrate against both the dealership and FCA. (Id.) FCA did not move to compel arbitration but instead filed a notice of non-opposition. (Id.) The Court of Appeal concluded that the trial court correctly determined that Plaintiff’s claims against FCA were encompassed by the arbitration agreement. (Id.) In reaching this conclusion, the Court of Appeal examined an identical arbitration clause which stated in pertinent part: “[A]ny claim or dispute, whether in contract, tort, statute or otherwise … between you and us … which arises out of or relates to … [the] condition of this vehicle, this contract or any resulting transaction  or relationship (including any such relationship with third parties who do not sign this contract) shall … be resolved by neutral, binding arbitration and not by a court action.” The appellate court found that the equitable estoppel doctrine applied: “The [buyers’] claim against [the manufacturer] directly relates to the condition of the vehicle that they allege to have violated warranties they received as a consequence of the sales contract. Because the [buyers] expressly agreed to arbitrate claims arising out of the condition of the vehicle — even against third party nonsignatories to the sales contract — they are estopped from refusing to arbitrate their claim against [the manufacturer]. Consequently, the trial court properly ordered the [buyers] to arbitrate their claim against [the manufacturer]. (Id. at pp. 496-497.) 

Moreover, before Felisilda was decided, the Court reached this same conclusion about the equitable estoppel theory in prior motions to compel arbitration brought in lemon law cases.

Under the doctrine of equitable estoppel, “a nonsignatory defendant may invoke an arbitration clause to compel a signatory plaintiff to arbitrate its claims when the causes of action against the nonsignatory are ‘intimately founded in and intertwined’ with the underlying contract obligations.” (JSM Tuscany, LLC v. Superior Court (2011) 193 Cal.App.4th 1222, 1237.) The doctrine applies in either of two circumstances: (1) when the signatory must rely on the terms of the written agreement containing the arbitration clause in asserting its claims against the nonsignatory or (2) when the signatory alleges “substantially interdependent and concerted misconduct” by the nonsignatory and a signatory and the alleged misconduct is “founded in or intimately connected with the obligations of the underlying agreement.” (Goldman v. KPMG, LLP (2009) 173 Cal.App.4th 209, 218-219.) At bottom, “[t]he linchpin for equitable estoppel is equity—fairness.”” (Id. at p. 220.) 

A review of longstanding precedent in California law reveals a strong interrelationship between warranties and underlying purchase agreements.  “A warranty is a contractual term concerning some aspect of the sale, such as title to the goods, or their quality or quantity.”  (Jones v. ConocoPhillips Co. (2011) 198 Cal.App.4th 1187, 1200 (emphasis added).)  “A warranty is as much one of the elements of sale and as much a part of the contract of sale as any other portion of the contract and is not a mere collateral undertaking.”  (A. A. Baxter Corp. v. Colt Industries, Inc. (1970) 10 Cal.App.3d 144, 153.)  To this point, in reviewing the Song-Beverly Act’s legislative history, the California Supreme Court has noted that “the Legislature apparently conceived of an express warranty as being part of the purchase of a consumer product.”  (Gavaldon v. DaimlerChrysler Corp. (2004) 32 Cal.4th 1246, 1258; see also Felisilda, supra, 53 Cal.App.5th at 496 (“[T]he sales contract was the source of the warranties at the heart of this case.”).) 

In view of this legal backdrop, the equitable estoppel doctrine applies in lemon law cases like this because the buyer relies upon the underlying purchase agreement to (1) establish standing, (2) invoke implied warranties, and (3) obtain remedies. 

Standing: Standing to bring Song-Beverly Act claims is limited to a “buyer of consumer goods” (Civ. Code § 1794(a)), which the Song-Beverly Act defines as “any individual who buys consumer goods from a person engaged in the business of manufacturing, distributing, or selling consumer goods at retail.”  (Civ. Code § 1791(b).)  Without this purchase agreement, Plaintiff cannot meet this standing requirement or, indeed, the standing requirement for any warranty claim.  (Jones, supra, 198 Cal.App.4th at 1201 (“As a general rule, a cause of action for breach of implied [or express] warranty requires privity of contract; ‘there is no privity between the original seller and a subsequent purchaser who is in no way a party to the original sale.’ ”).)

Implied Warranties: The implied warranty of merchantability attaches to “every sale of consumer goods that are sold at retail in this state,” unless properly disclaimed.  (Civ. Code § 1792.)  Without the Sales Contract, Plaintiff would have no implied warranties to invoke.

Remedies:  According to the Complaint, Plaintiff seeks to “reimbursement” for the costs of financing, and owning the Vehicle and “rescission” of the purchase agreement of the Vehicle.  (Complaint. ¶¶ 71, 76, 94-96, Prayer for Relief No.2.)  These remedies require examination and presentation of the Sales Contract.

Because the Sales Agreement underlies Plaintiff’s causes of action, the equitable estoppel doctrine must apply.

In opposition, Plaintiff contends that NNA’s motion must be denied firstly because NNA has waived the right to arbitrate under the guidance provided by federal authority, pointing to federal precedent to suggest NNA’s delay of several months to be conclusive of its waiver of any right to arbitrate these claims. (Opposition, 2-6; citing Morgan v. Sundance, Inc. (2022) 142 S.Ct. 1708.)

Second, Plaintiff contends the motion must be denied because NNA is a non-signatory to the Agreement. (Opp., 6-9.) Plaintiff also points to the specific “you” or “we” language of the Arbitration provision as limiting definitions, which reflect what parties were intended on being included in the Agreement. (Id.) However, the underlined portions of the Agreement specifically consider and highlight an inclusion of any “relationship” “with third parties who do not sign this contract,” which this court reads to specifically consider and include third parties which may have a beneficiary relationship as a result of the Agreement. Further, as this court has discussed above, binding California authority, and a reading of California law, shows the nonsignatory defendant, NNA, can compel arbitration as Plaintiff’s claims are sufficiently “intertwined” with its contractual obligations.

Additionally, Plaintiff contends that since the FAA applies, then federal precedent supports a contrary holding to Felisilda, which Plaintiff also contends does not apply. (Opp., 7-9.) This court finds Plaintiff’s reliance on federal authorities that reach a contrary conclusion unpersuasive. (See, e.g., Ngo v. BMW of North America, LLC (9th Cir. 2022) 23 F.4th 942.)

Plaintiff argues that Felisilda is distinguishable because the buyers in that case brought claims against both the dealership and manufacturer whereas here the claims are brought solely against the manufacturer. This is a distinction without a meaningful difference. The reasoning in Felisilda for upholding the equitable estoppel finding was that the buyers’ claims related to the condition of the subject vehicle and the buyers expressly agreed to arbitrate their claims arising out of the condition of the subject vehicle, including those against third party nonsignatories to the sales contract. The same rationale is found here in these circumstances, with this Agreement. Further, the FAA does not “alter background principles of state contract law regarding the scope of agreements (including the question of who is bound by them).”  (Arthur Andersen LLP v. Carlisle (2009) 556 U.S. 624, 630.)¿ As opposed to the California Court of Appeal ruling in Felisilda, Ngo is not binding on this court and provides persuasive authority only. (See¿Felisilda, supra, at 497.)¿ The Court does not find Ngo more persuasive than binding authority in Felisilda.  Because state law determines whether a nonsignatory party may compel arbitration, the court rejects Plaintiff’s argument that the choice-of-law provision in the arbitration agreement here precludes the applicability of Felisilda

Additionally, Plaintiff contends equitable estoppel does not apply here, since:

“Plaintiff’s Complaint alone makes clear that the claims against NNA did not intimately rely upon the obligations set forth in the sales contract, and were not intertwined with those obligations. Rather, Plaintiff’s claims are fully viable and independent of the sales contract... Plaintiff did not sue NNA for breach of contract, and instead asserted statutory claims for violations of the Song-Beverly Act. Under California law, warranties from a manufacturer that is not a party to a sales contract are ‘not part of [the] contract of sale.’... NNA has provided zero evidence of any proven close relationship between it and Nissan of Alhambra, an individually owned dealership, such as ... of one of parent and owned subsidiary or a non-signatory successor that shared a common owner with the signatory. There is no affidavit or documentation filed with NNA’s Motion showing a close relationship between NNA and the selling dealership. Thus, ‘the inequities that the doctrine of equitable estoppel is designed to address are not present.’” (Opp., 9-15; citing Jarboe v. Janless Auto Group (2020) 53 Cal.App.5th 539 (Jarboe).)

In Jarboe, Plaintiff, who was terminated from an automobile dealership, brought a wage and hour action individually and on behalf of a putative class against his former employer and affiliated dealerships. (Jarboe, supra, 53 Cal.App.5th at 543-544.) The trial court granted Defendants’ motion to compel arbitration as to 11 out of 12 causes of action against the employer and denied the motion as to the request for a stay and as to the other defendants. (Id.) The Court of Appeal found that the trial court correctly rejected Defendants’ arguments about standing to compel arbitration as third-party beneficiaries and under the theory of equitable estoppel. (Id. at 547.) According to the Court of Appeal, even if the other owners had standing to compel arbitration under the operative agreement, it is limited to the “context of their ownership” of the company named in the employment agreement also at issue. (Id. at 550.) Additionally, the Jarboe court concluded that it was correct to refuse to compel arbitration against the other defendants because there was no showing that plaintiff’s claims against these other defendants are “rooted” in his employment with his former employer or his agreement to arbitrate with his former employer. (Id. at 552-556.)

In reply, NNA correctly contends that NNA has standing to move to compel arbitration as a third-party beneficiary of the Agreement because the FAA does not alter principles of California contract law. (Reply, 3-7; citing Arthur Andersen LLP v. Carlisle, (2009) 556 U.S. 624, 630.) According to NNA, any breach of express warranty claim is tethered to the Agreement because without the Agreement, Plaintiff would not have received the warranty. (Reply, 5-7.)

Plaintiff’s fraudulent omission claim also arises out of and relates to the purchase and condition of the Subject Vehicle. (Orozco v. WPV San Jose LLC (2019) 36 Cal.App.5th 375, 411.) Without a purchase, Plaintiff would lack any basis for his fraudulent inducement claims.” (Id.; citing Metalclad Corp. v. Ventana Env't Organizational P’ship, (2003) 109 Cal.App.4th 1705, 1718.)

NNA also contends that Plaintiff’s claims are intertwined with the Agreement because the Song-Beverly Act expressly provides that it only applies to consumers who purchase a vehicle from a retail seller within the meaning of the Song-Beverly Act, pursuant to Felisilda. (Id.)

The court agrees with NNA that Felisilda applies and gives NNA standing to move to compel arbitration in this action. Pursuant to Felisilda, NNA has standing to compel arbitration if Plaintiff’s claims relate to the condition of the vehicle and Plaintiff has agreed to arbitrate claims arising out of the condition of the vehicle. Further, the court concludes that Jarboe does not conflict with Felisilda. Instead, Jarboe held that arbitration could not be compelled against non-signatory companies because there was no showing that plaintiff’s claims arise out of his employment with his former employer or his agreement to arbitrate with his former employer. Thus, Felisilda and Jarboe stand for the same principles.

As discussed above, the Agreement provides in pertinent part that Plaintiff agrees to arbitrate claims “which arise out of or relate to  your credit application, purchase or condition of this vehicle, this contract or any resulting transaction or relationship (including any such relationship with third parties who do not sign this contract).” Thus, Plaintiff has agreed to arbitrate claims arising out of or relating to the “condition” of the Vehicle, or any resulting “relationship,” including any relationship with “third parties who do not sign the contract,” such as NNA.

For these reasons, the court finds that a valid agreement to arbitrate exists which applies to all of Plaintiff’s claims against NNA in this action. The court will now analyze the parties’ arguments regarding defenses to enforcement.

III.             Defenses to Enforcement

 

A.     Procedural & Substantive Unconscionability

 

Pursuant to Armendariz v. Foundation Health Psychcare Services, Inc. (2000) 24 Cal.4th 83, 114 (Armendariz) both procedural and substantive unconscionability must be present in order for a court to exercise its discretion to refuse to enforce a valid arbitration agreement. Additionally, in Armendariz, the California Supreme Court recognized that it is more appropriate to sever and restrict illegal terms that are collateral to the main purpose of a contract than to find the entire contract invalid.  (Armendariz, supra, 24 Cal.4th at 124 [“Courts are to look to the various purposes of the contract.  If the central purpose of the contract is tainted with illegality, then the contract as a whole cannot be enforced.  If the illegality is collateral to the main purpose of the contract, and the illegal provision can be extirpated from the contract by means of severance or restriction, then such severance and restriction are appropriate.”].)

 

In opposition, Plaintiff contends the purchase agreements for vehicle purchases “are routinely presented to auto consumers as a ‘take it or leave it’ agreement...” and NNA has “essentially forced Plaintiff to waive his statutory rights under the Song-Beverly Act.” (Opp., 17-18.) In reply, however, NNA has correctly explained “California courts have recognized the fact that contract is one of adhesions ‘does not by itself render it unenforceable as unconscionable.” (Reply, 8; citing Fisher v. MoneyGram Int’l, Inc. (2021) 66 Cal.App.5th 1084, 1095.) Defendant contends Plaintiff has failed to make a showing of procedural unconscionability “based on his own particular transaction.” (Id.; citing Crippen v. Cent. Valley RV Outlet (2004) 124 Cal.App.4th 1159, 1165.) The court agrees. Plaintiff has failed to refer to his specific circumstances and point to particular unfairness in the contracting terms of the Arbitration Agreement. Therefore, Plaintiff has failed to make a showing of procedural unconscionability.

 

Plaintiff next points to language requiring Defendants’ approval of the arbitration and the denial of a jury trial as substantive unconscionability. (Opp., 18.) Plaintiff also points to an alleged cost-shifting clause regarding the dealership as another example of substantive unconscionability. (Opp., 18-19.) Lastly, Plaintiff points to the bilateral terms of the Arbitration Agreement as substantively unconscionable, as the resources of Defendants may be drastically different than that of Plaintiff, and may therefore allow Defendants to avail themselves of other remedies. (Opp., 19.)

 

In reply, NNA correctly explains that Plaintiff may “choose either AAA,” or “any other organization subject” to NNA’s approval, and Plaintiff is “thus free to propose any forum as long as there is mutual consent.” (Reply, 8-9.) NNA also correctly explains that a waiver of a jury trial, and thus selecting an alternative forum, is one of the purposes of such an arbitration provision and “Plaintiff cites no authority ... to suggest that the waiver of such a right by parties selection arbitration instead somehow renders the provision unconscionable.” (Reply, 9.)

 

Next, NNA also correctly explains Plaintiff’s mischaracterization of the Agreement’s language, as included above, which expressly states:

 

“We will pay your filing, administration, service or case management fee and your arbitrator and hearing fee and any arbitration appeal fees you incur all up to a maximum of $5000, unless the law or the rules of the chosen arbitration organization require us to pay more.” (Richardson Decl., Exh. 1.)

Lastly, NNA contends none of the bilateral provisions are unconscionable as “Plaintiff leaves out” Defendant’s responsibility to reimburse Plaintiff for any filing fees and Plaintiff’s right to seek individual injunctive relief in court. (Reply, 9-10.) The court agrees. Plaintiff has failed to cite persuasive authority, or language in the Agreement, to show both procedural and substantive unconscionability.

 

Because both substantive and procedural unconscionability are required before the court may refuse to enforce a valid arbitration agreement, and Plaintiff has failed to make a showing of either and both, NNA’s motion is granted.

 

Conclusion

 

NNA’s motion is granted. Plaintiff is ordered to arbitrate his claims against NNA. This action is stayed pending completion of arbitration or further order of the court. The court sets an order to show cause re status of the arbitration for January 24, 2024, at 8:30 a.m. in Department 37. NNA is to give notice.