Judge: Gary I. Micon, Case: 24CHCV02172, Date: 2025-02-25 Tentative Ruling

Case Number: 24CHCV02172    Hearing Date: February 25, 2025    Dept: F43

Dept. F43

Date: 02-25-25

Case # 24CHCV02172, Barragan v. Kohl’s, Inc.

Trial Date: None set.

 

PETITION TO COMPEL ARBITRATION

 

MOVING PARTY: Defendant Kohl’s Inc.

RESPONDING PARTY: Plaintiff Vanessa Barragan

 

RELIEF REQUESTED

Order compelling arbitration and staying this action.

 

RULING: Motion is granted.

 

SUMMARY OF ACTION

Plaintiff Vanessa Barragan (Plaintiff) sued defendant Kohl’s, Inc. (Defendant) on June 12, 2023, alleging causes of action for (1) disability discrimination; (2) sex/gender discrimination; (3) pregnancy discrimination; (4) harassment – hostile work environment; (5) intentional infliction of emotional distress; (6) negligent hiring, supervision, retention; (7) failure to prevent discriminatory practices; (8) FEHA retaliation; (9) Labor Code § 1102.5 retaliation; (10) wrongful termination; and (11) Unlawful business Practices.

 

Plaintiff alleges that she was employed with Defendant from October 2023 until December 29, 2023 when Defendant terminated her employment.  On November 27, 2023, Plaintiff woke up feeling sick, went to urgent care where she found out she was pregnant, went home to get rest as instructed, and informed her supervisor about the pregnancy.  Two days later, Plaintiff suffered a miscarriage and texted her supervisory about the miscarriage.  After Plaintiff inquired about sick leave, her supervisor told her to get a doctor’s note excusing her absence from work.  Plaintiff procured a doctor’s note placing her off work from November 27, 2023 through December 1, 2023.  After Plaintiff returned to work on December 4, 2023, Defendant’s employees displayed hostility towards her.

 

On July 26, 2024, Defendant filed a petition to compel arbitration of Plaintiff’s claims according to an arbitration agreement Plaintiff signed on November 2, 2023.

 

Plaintiff filed an opposition contending that Plaintiff did not knowingly agree to arbitrate claims against Defendant because Plaintiff was never informed that she was signing a document which waived her legal rights and access to the courts as a condition of employment and does not recall signing the agreement.  The arbitration agreement is procedurally unconscionable because Defendant presents no evidence that Plaintiff could have negotiated the terms of the agreement or that the opt-out provision was considered an actual option.  Plaintiff was required to sign all documents in less than 45 minutes to proceed with training without being given an opportunity to ask any questions prior to signing the documents, and Defendant did not give Plaintiff a copy of the arbitration rules.  The agreement is substantively unconscionable because it requires the parties to share the cost of arbitration in violation of Armendariz.  Further, the terms of the arbitration agreement are unfairly biased towards Defendant because the agreement prevents Plaintiff from seeking relief through a judge, jury, or in a class action lawsuit.  The arbitration agreement is invalid even if the numerous unconscionable terms are severed.

 

Defendant replies contending that the arbitration agreement is valid and that opposing counsel purposefully mischaracterizes Melissa Fimrite’s declaration regarding Defendant’s onboarding process for new hires after April 2021.  Defendant’s supplemental reply, filed February 11, 2025, contends that Plaintiff contradicts herself by stating she does not recall signing the arbitration agreement while also stating she signed a packet of documents she received electronically.  Plaintiff fails to establish unconscionability because the arbitration agreement allowed Plaintiff to choose her arbitration provider and rules.  The arbitration agreement contains a provision stating how an individual may opt-out of the agreement and includes a provision stating which procedures would be used and linked to the relevant websites containing the procedures.  Failing to attach or incorporate rules to the agreement is insufficient to find procedural unconscionability.  Further, the arbitration agreement states that the parties share the costs of arbitration unless binding precedent requires one party to bear all or the greater share of the arbitration costs.  Armendariz’s holding regarding arbitration fees applies only in cases where the employer imposes mandatory arbitration as a condition of employment.  Arbitration was never a condition of Plaintiff’s employment because, as the arbitration agreement states, she could have opted out of the agreement.  Employment arbitration agreements with class waivers such as the one in Section 11 of the Agreement are enforceable in California.

 

ANALYSIS

 

Evidentiary Objections to the Declaration of Melisa Fimreite: Overruled.

 

Legal Standard 

Civil Procedure Code section 1281.2 empowers the Court to compel parties to arbitrate disputes pursuant to an agreement to do so.  “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 revocation of the agreement.”  (Code Civ. Proc., § 1281.2, subds. (a), (b).)

 

California law incorporates many of the basic policy objectives contained in the Federal Arbitration Act, including a presumption in favor of arbitrability.  (Engalla v. Permanente Medical Group, Inc. (1997) 15 Cal.4th 951, 971-972.)  The petitioner bears the burden of proving the existence of a valid arbitration agreement by the preponderance of the evidence, the party opposing the petition then bears the burden of proving by a preponderance of the evidence any fact necessary to demonstrate that there should be no enforcement of the agreement, and the trial court sits as a trier of fact to reach a final determination on the issue.  (Rosenthal v. Great Western Financial Securities Corp. (1996) 14 Cal.4th 394, 413.)

 

Under both the Federal Arbitration Act and California law, arbitration agreements are valid, irrevocable, and enforceable, except on such grounds that exist at law or equity for voiding a contract.  (Winter v. Window Fashions Professions, Inc. (2008) 166 Cal.App.4th 943, 947.)  The party moving to compel arbitration must establish the existence of a written arbitration agreement between the parties.  (Code Civ. Proc., § 1281.2.)  This is usually done by presenting a copy of the signed, written agreement to the court and by including the provisions of the arbitration agreement that provide for arbitration in the petition.  (Cal. Rules of Court, rule 3.1330.)  The moving party must also establish the other party’s refusal to arbitrate the controversy.  (Code Civ. Proc., § 1281.2; Espejo v. Southern California Permanente Medical Group (2016) 246 Cal.App.4th 1047, 1060; see also Bannister v. Marinidence Opco, LLC (2021) 64 Cal.App.5th 541; Hyundai Amco America, Inc. v. S3H, Inc. (2014) 232 Cal.App.4th 572, 577 [filing a lawsuit against the moving party for claims within the scope of the arbitration agreement].)

 

Defendant asserts that Plaintiff acknowledged Defendant’s Dispute Resolution Policy (DRP) and electronically signed a copy of the policy titled AR236 - Kohl’s Dispute Resolution Policy (Arbitration Agreement) on November 2, 2023 during Plaintiff’s new employee onboarding process.  (Declaration of Melisa Fimreite, ¶ 14, p. 18.)  To support this assertion, Defendant presents the declaration of Melisa Fimreite, Manager in the Human Resources Compliance department for Defendant.  (Fimreite Dec., ¶ 1.)  Ms. Fimreite has worked for Defendant since February 2009 and has held her current position since January 2023.  (Ibid.)

 

Ms. Fimreite is responsible for creating, implementing, and maintaining the electronic system used to provide new employees with documents and trainings during the orientation and onboarding process through the human resource information system called CIC+.  (Fimreite Dec., ¶ 4.)  The CIC+ system allows Defendant’s employees to electronically manage certain personnel matters during onboarding for their employment, including distribution of certain workplace policies such as the DRP.  (Fimreite Dec., ¶ 6.)  An employee’s record of forms completed through CIC+ is accessible by the employee and certain Human Resources personnel, such as Ms. Fimreite, through Workday and CIC+.  (Fimreite Dec., ¶ 8.)  The documents and records maintained in CIC+ are maintained in the ordinary course of Defendant’s business and reflect true and correct copies of documents created or acknowledged by employees with a duty to do so.  (Fimreite Dec., ¶ 9.)

 

As part of her duties, Ms. Fimreite regularly accesses employee records that were submitted as part of the onboarding process in CIC+.  (Fimreite Dec., ¶ 5.)  Ms. Fimreite is also responsible for administering the DRP to new employees during the onboarding process.  (Fimreite Dec., ¶ 6.)  Defendant implemented this DRP in September 2020 to all onboarding employees through its CIC+ program, and Defendant has not amended or modified the DRP since April 2021.  (Fimreite Dec., ¶ 6.) 

 

When a new employee is hired, they are required to participate in an orientation session, also referred to as onboarding.”  (Fimreite Dec., ¶ 7.)  Defendant uses the Workday system to facilitate the onboarding process.  (Fimreite Dec., ¶ 7.)  Prior to the orientation session, every employee is assigned a unique Workday profile that can only be accessed with a username and password assigned to that individual.  (Fimreite Dec., ¶ 7.)  At orientation, a new employee populates their Workday profile with certain required demographic and payroll information and is presented with a “Compliance EForm” section prompt in Workday.  (Fimreite Dec., ¶¶ 7-8.)  Clicking on the Compliance EForm tab sends the employee to Defendant’s CIC+ system to review, acknowledge, and execute certain online employee company policies, including the DRP which is labeled as AR256 - Kohl’s Dispute Resolution Policy.  (Fimreite Dec., ¶¶ 8, 10.) 

 

At orientation, the employee is required to click on the DRP which presents the employee with a copy of the DRP.  (Fimreite Dec., ¶ 10.)  Employees are required to acknowledge and review the DRP but not as a condition of employment with Defendant because the DRP contains a provision giving employees 30 calendars from the day they received notice of the DRP to elect not to be bound by the DRP or its choice of law provision.  (Fimreite Dec., ¶ 16.)  The DRP also states how to opt out of the DRP.  (Fimreite Dec., ¶ 16, Exh. A, p. 15.)  After the employee reviews the DRP, they must “acknowledge” and click a box stating they “received, read, and understood the DRP” and that “By selecting ‘Submit to Employer’ you agree that your completed form will be electronically signed and submitted to your employer.”  (Fimreite Dec., ¶ 11.)  The employee then clicks “Submit to Employer.”  (Fimreite Dec., ¶ 11.)  Once the employee clicks the box to “consent” to the DRP, their signature is electronically affixed to the document, and CIC+ captures the exact time and date the employee clicked the consent box and affirmatively consented to the DRP.  (Fimreite Dec., ¶ 12.)

 

Ms. Fimreite accessed Plaintiff’s records in Workday and CIC+, and the records reflect that the DRP Compliance EForm was accessed, reviewed, acknowledged, and executed on November 2, 2023, at 4:31 P.M. Eastern Standard Time.  (Fimreite Dec., ¶¶ 13-14, Exh. A., p. 18.)  Only Plaintiff could have accessed the screens she viewed to electronically acknowledge the DRP by first logging into Workday using her unique log-in credential.  (Fimreite Dec., ¶ 15.) 

 

The Arbitration Agreement states in relevant part:

 

1.       [M]andatory final and binding individual arbitration . . . or a Small Claims Court action, as applicable, are the sole and exclusive remedies for formal resolution of all unresolved Covered Disputes . . . .

 

* * * *

 

3.       WHAT TYPES OF DISPUTES ARE COVERED BY THE DRP? This DRP applies only to “Covered Disputes,” which are defined to mean any and all claims, causes of action, or other disputes or controversies that have already accrued, now exist, or arise in the future between a Covered Individual and Company and/or between Covered Individuals based on any legal, equitable, or other ground or theory (including whether any such ground or theory constitutes an unwaivable statutory right) and would be cognizable and could be properly brought in a federal, state, or local court or agency under applicable laws. Unless falling within the definition of Excluded Disputes, below, Covered Disputes include those arising out of or related to (i) a Covered Individual’s employment with or work for Company, applying for or seeking or being denied such employment or work, the termination of such employment or work, and/or any of the terms, conditions, or benefits of such employment or work (including any wage and hour issues), (ii) issues of arbitrability (such as the formation, interpretation, applicability or enforceability of this DRP, except to the extent they are Excluded Disputes), (iii) the procedures to be followed in the arbitration proceedings other than any that would allow a Representative Action, Mass Arbitrations or a PAGA Action (all as defined below), (iv) allegations of delay and waiver, (v) whether prerequisites such as time limits, notice, laches, estoppel, and other conditions precedent to an obligation to arbitrate have been met, and (vi) any disputes over the payment and/or apportionment of the arbitration forum costs (including arbitrator fees), including as to whether the arbitration forum costs provisions of this DRP are unconscionable under applicable law. Subject to the provisions of Sections 11, 12 and 26 of this DRP, Covered Disputes include those that (a) arose or accrued before and/or arise or accrue after the date of becoming bound by this DRP, including those that are the subject of or asserted in a previously-threatened or filed and/or currently-pending Representative Action or PAGA Action (both as defined below) in which no class or collective certification has been granted or no trial has been commenced by the court as of the date of becoming bound by this DRP,2 and/or in any subsequently-threatened or filed Representative Action or PAGA Action (both as defined below), (b) arise or accrue before, upon, or after a Covered Individual’s employment with or work for Company terminates or his/her application for employment or work is denied, and/or (c) concern or relate to whether a Covered Individual has suffered and/or is suffering or was and/or is subjected to any violation(s) or breach(es) of any legal obligations, including declaratory relief to resolve that issue. Covered Disputes must only be heard and decided by the appointed arbitrator.

 

4.       WHAT TYPES OF DISPUTES ARE NOT COVERED BY THE DRP? This DRP does not apply to “Excluded Disputes,” which are defined to mean: (i) claims for workers’ compensation benefits under state law; (ii) claims for unemployment or disability insurance or other health or welfare benefits under government-administered programs; (iii) claims arising under a pension, retirement, or other health and welfare benefit plan that contains an arbitration or other dispute resolution procedure; (iv) claims within the jurisdiction of the National Labor Relations Board; (v) claims arising or regulated under federal law for which there is an unwaivable specific statutory or regulatory enactment making such claims not arbitrable; (vi) exhausting administrative remedies or notice requirements, and/or participating in government proceedings, as provided in Sections 16 and 25 of this DRP; (vii) claims for temporary or provisional equitable relief in aid of arbitration under this DRP, as permitted under applicable law, which may be brought either before the appointed arbitrator or a court of competent jurisdiction; (viii) disputes regarding the applicability, interpretation, enforceability, and/or severability of the provisions of Sections 11, 12 and 26 of this DRP, including whether such provisions are governed by the Federal Arbitration Act, which must be decided only by a court of competent jurisdiction; (ix) disputes as to whether Company and any Covered Individual agreed to allow any Representative Action, PAGA Action or alleged Mass Arbitrations (all as defined below) to be arbitrated under this DRP, which must be decided only by a court of competent jurisdiction; (x) claims or disputes required to be grieved and/or arbitrated under the terms of an applicable collective bargaining agreement, if any; and (xi) any disputes as to whether any claims or disputes are Excluded Disputes, which must be decided only by a court of competent jurisdiction.

 

* * * *

 

7.   The Parties waive any and all rights to a judge or jury trial and/or administrative hearing of their own Covered Disputes and agree to their resolution exclusively by final and binding individual arbitration . . . , whether initiated by any Covered Individual or by Company . . . .

 

10. WHAT ARBITRATION RULES AND PROCEDURES WILL APPLY? The Federal Rules of Civil Procedure (the “FRCP”) and the Federal Rules of Evidence (“FRE”) (both of which are accessible via links at http://www.uscourts.gov/RulesAndPolicies/rules/current-rules.aspx), are incorporated into this DRP and will apply to and must be followed and enforced by the appointed arbitrator in any arbitration proceedings.  The Parties will have the right to make offers of judgment . . . .

 

* * * *

 

13. HOW DOES THE ARBITRATOR DECIDE COVERED DISPUTES? . . . . The arbitrator will be empowered to award either Party . . . any individual remedy that otherwise would have been available to the Party on an individual basis under applicable law.

 

* * * *

 

18. IS THERE A WAY TO OPT-OUT OF THE DRP OR ITS CHOSEN STATE LAW?  Not later than the 30th calendar day after the date the Covered Individual has received notice or a copy of this DRP (the “Election Deadline”), the Covered Individual can elect to not be bound by this DRP or its Chosen State Law provision by giving Company written notice of such election (an “Election Notice”). Before deciding whether to give Company an Election Notice, the Covered Individual is being provided with this 30-day opportunity to consult with an attorney and/or other advisors of the Covered Individual’s choosing.

 

* * * *

 

26. ARE PAGA ACTIONS ALLOWED FOR CALIFORNIA COVERED INDIVIDUALS? [T]he right for either me or the Company to pursue Covered Disputes through a judge or jury trial in court and/or on a class, collective or any other type of representative action basis or as part of any Mass Arbitrations is otherwise waived.

 

(Fimreite Dec., Exh. A, pp. 1-2, 8, ¶¶ 1, 3, 7, 10, 13, 18, 26.)

 

The Arbitration Agreement appears to bear the electronic signature “vanessa barragan,” Plaintiff’s name, in the signature block with the date “11/02/2023” and the time “04:41 PM ET.”  (Fimreite Dec., Exh. A, at p. 18.) 

 

Defendant has met its initial burden by attaching an arbitration agreement purportedly bearing Plaintiff’s electronic signature.

 

In opposition, Plaintiff states that she does not remember signing the arbitration agreement, that she never knowingly agreed to arbitrate claims against Defendant, Defendant never informed Plaintiff that signing the Arbitration Agreement was voluntary and that she could consult with a lawyer, and that Defendant told Plaintiff she had to sign all paperwork if she wanted her job.  (Declaration of Vanessa Barragan, ¶¶ 2-7.)  Plaintiff further contends that the Fimreite Declaration fails to provide a sufficient foundation for Fimreite’s knowledge of the procedures in maintaining the electronic system used to provide new employees with documents and her declarations that Plaintiff’s record reflects that Plaintiff electronically signed the Arbitration Agreement.  Finally, Ms. Fimreite declares she became manager of the Human Resources Compliance department in January 2023, over two years after Plaintiff’s onboarding. 

 

Plaintiff’s arguments lack merit because the Fimreite Declaration states a foundation for explaining how Defendant maintains its personnel records, how new employees access, review, and sign company policies and forms, and Ms. Fimreite has been the Manager of Defendant’s Human Resources Compliance Department since January 2023, over six months before Plaintiff admits she began working for Defendant.  Further, Plaintiff presents no evidence to support her arguments that she does not remember signing the Arbitration Agreement and did not know she could consult with a lawyer before signing the agreement even though the agreement explicitly states as much in paragraph 18’s opt-out provision and Plaintiff was required to acknowledge reading, reviewing, and understanding the agreement before submitting her acknowledgment and signature to Defendant.  (Fimreite Dec., ¶¶ 13-17.)  Although new employees were required to acknowledge the DRP, signing the DRP was not a condition of employment as evidenced by paragraph 18.

 

Accordingly, the evidence strongly suggests that a valid arbitration agreement exists, and that Plaintiff signed the agreement on November 2, 2023. 

 

            Applicable Law

Defendant argues the Federal Arbitration Act (FAA) applies to the Arbitration Agreement per the agreement’s terms and because the “Parties agree that [Defendant] is engaged in transactions involving interstate commerce.”  (Fimreite Dec., Exh. A, ¶ 17.)  Plaintiff does not dispute whether the FAA or California law applies.  California law provides that the parties may expressly designate that an arbitration proceeding should move forward under the FAA’s procedural provisions rather than under state procedural law.  (Cronus Investments, Inc. v. Concierge Services (2005) 35 Cal. 4th 376, 394).

 

Accordingly, the FAA applies to the Arbitration Agreement.

 

            Enforceability of the Arbitration Agreement - Unconscionability

Once an arbitration agreement is presented to the Court, the burden shifts to the opposing party to challenge the agreement’s enforceability with evidence.  (Baker v. Italian Maple Holdings, LLC (2017) 13 Cal.App.5th 1152, 1160.)  Plaintiff argues the Arbitration Agreement is unconscionable.

 

“California courts analyze unconscionability as having a procedural and a substantive element.”  (Kinney v. United Healthcare Services, Inc. (1999) 70 Cal.App.4th 1329.)  The doctrine of unconscionability refers to “an absence of meaningful choice on the part of one of the parties together with contract terms which are unreasonably favorable to the other party.”  (Sonic-Calabasas A, Inc. v. Moreno (2013) 57 Cal.4th 1109, 1133.)  It consists of procedural and substantive components, “the former focusing on oppression or surprise due to unequal bargaining power, the latter on overly harsh or one-sided results.”  (Ibid.)  Although both components of unconscionability must be present to invalidate an arbitration agreement, they need not be present to the same degree.  (Armendariz v. Found Health Psychcare Servs., Inc. (2000) 24 Cal.4th 83, 114.)  “In other words, the more substantively unconscionable the contract term, the less evidence of procedural unconscionability is required to come to the conclusion that the term is unenforceable, and vice versa.”  (Ibid.)  “The party resisting arbitration bears the burden of proving unconscionability.”  (Pinnacle Museum Tower Assn. v. Pinnacle Market Dev. (US), LLC (2012) 55 Cal.4th 223, 247.)

 

            1.  Procedural Unconscionability

“Procedural unconscionability concerns the manner in which the contract was negotiated and the circumstances of the parties at that time.  It focuses on factors of oppression and surprise.”  (Pinnacle Museum Tower Assn. v. Pinnacle Market Dev. (US), LLC (2012) 55 Cal.4th 223, 247.)  “Surprise differs from oppression. Surprise is when a prolix printed form conceals the arbitration provision.  [Citation.]  Oppression, on the other hand, occurs when there is a lack of negotiation and meaningful choice.  [Citation.]  The presence of surprise or oppression requires higher scrutiny of the contract.”  (Torrecillas v. Fitness International, LLC¿(2020) 52 Cal.App.5th 485, 493.)

 

Plaintiff contends that the Arbitration Agreement is procedurally unconscionable per se because the Arbitration Agreement was a contract of adhesion.

 

“Adhesion contracts are form contracts a party with superior bargaining power offers on a take-it-or-leave-it basis.”  (Torrecillas, supra, 52 Cal.App.5th at p. 493.)  Where a contract of adhesion includes the unequal bargaining power of contracting parties, with the weaker party’s inability to negotiate, this may indicate procedural unconscionability in the form of surprise or oppression.  (See Thompson v. Toll Dublin, LLC (2008) 165 Cal.App.4th 1360, 1372.)  In the absence of “surprise or other sharp practices,” courts do not recognize that “adhesive” arbitration agreements establish a high degree of procedural unconscionability.  (Baltazar v. Forever 21 Inc. (2016) 62 Cal.4th 1237, 1246.)

 

The Arbitration Agreement is not an adhesion contract.  The Arbitration Agreement allowed Plaintiff to opt out by mailing or sending an email to Defendant’s General Counsel at Legal@kohls.com within 30 days of receiving notice of or a copy of the DRP, which further minimized any degree of procedural unconscionability.  (Fimreite Dec., Exh. A, ¶ 18.)  Further, Defendant contends that signing the Arbitration Agreement was not a condition of Plaintiff’s employment, but that Plaintiff was required to acknowledge that she read, reviewed, and understood Defendant’s DRP, which Plaintiff did.

 

Plaintiff also contends that she was required to sign all documents in her Workday account in less than 45 minutes before new employee orientation and that she was not given an opportunity to ask questions before signing the documents.  (Supplemental Barragan Dec., ¶ 2.)

 

Regardless, the fact that the Arbitration Agreement may have been presented on a take-it or leave-it basis or that there is unequal bargaining power only establishes at most a modest degree of procedural unconscionability, which Plaintiff has not established here.  (Torrecillas, supra, 52 Cal.App.5th at p.493; Baltazar v. Forever 21 Inc., supra, 62 Cal.4th at p.1246.)  Plaintiff fails to point to any section of the Arbitration Agreement that was a “surprise.”  The agreement specified at the top in capital lettering that the document contained Defendant’s Dispute Resolution Policy and that the signing party was bound by the policy unless the party elected not to be bound by it.  (Fimreite Dec., Exh. A, p. 1.)  Although Plaintiff alleges she did not read the Arbitration Agreement, Plaintiff fails to show that Defendant prevented her from doing so or that Plaintiff even requested assistance with understanding the Arbitration Agreement.

 

Finally, Plaintiff contends that Defendant did not give Plaintiff a copy of the arbitration rules.  Plaintiff cites Trivedi v. Curexo Technology Corp. (2010) which held that a mandatory arbitration clause that referenced the American Arbitration Association’s (AAA) rules was procedurally unconscionable because the rules were not attached to the agreement and that the bound party was required to find the rules in another source.  (189 Cal.App.4th 387, 393.)  Although failure to attach arbitration rules could factor into finding procedural unconscionability, this alone is insufficient to sustain a finding of procedural unconscionability unless it would result in surprise to the opposing party.  (Lane v. Francis Capital Management LLC (2014) 224 Cal.App.4th 676, 690.)  The Arbitration Agreement expressly incorporates the Federal Rules of Civil Procedure and the Federal Rules of Evidence, and the Arbitration Agreement includes a link to both sets of rules.  (Fimreite Dec., Exh. A, ¶ 10.)  Although the rules are not attached to the Arbitration Agreement, Plaintiff presents no evidence of surprise or oppression because the rules are stated on the face of the agreement and the agreement is not one of adhesion.

 

Given the lack of evidence of procedural unconscionability, the Court finds that the arbitration agreement has at most a minimal degree of procedural unconscionability.  However, “a finding of procedural unconscionability does not mean that a contract will not be enforced, but rather that courts will scrutinize the substantive terms of the contract to ensure they are not manifestly unfair or one-sided.”  (Sanchez v. Valencia Holding Co., LLC (2015) 61 Cal.4th 899, 915.)

 

            2.  Substantive Unconscionability

“Substantive unconscionability” focuses on the terms of the arbitration agreement and whether those terms are “overly harsh or one-sided.”  (Kinney, supra, 70 Cal.App.4th at p. 1330; Carmona v. Lincoln Millennium Car Wash, Inc.¿(2014) 226 Cal.App.4th 74, 85).

 

“Where a party seeks to arbitrate nonwaivable statutory civil rights in the workplace, such as the FEHA claims and wrongful termination claim[s] . . . there are five minimum requirements for the lawful arbitration of such rights pursuant to a mandatory employment arbitration agreement”: (1) neutral arbitrators, (2) more than minimal discovery, (3) requires a written award sufficient for judicial review, (4) provides for all types of relief otherwise available in court, and (5) does not require employees to pay either unreasonable costs or arbitrator’s fees or expenses as a condition of access the arbitration forum.  (Armendariz v. Foundation Health Psychcare Service, Inc. (2000) 24 Cal.4th 82, 102.)  When there is little procedural unconscionability, a party opposing arbitration must show substantial substantive unconscionability.  (Id. at p. 114.)

 

Plaintiff contends that the Arbitration Agreement is substantively unconscionable because it requires the parties to share the cost of arbitration, and the terms of the arbitration agreement unfairly bias Defendant regarding waiving class actions and choosing the arbitrator.  Defendant opposes contending that the Arbitration Agreement states that the parties share the costs of arbitration unless binding precedent requires one party to bear all or the greater share of the arbitration costs including Armendariz which only applies to agreements involving mandatory arbitration as a condition of employment, and the class waiver does not favor Defendant but is enforceable under California law.  The covered disputes require Plaintiff to arbitrate claims only employees would bring against employers.

 

Armendariz’s holding regarding arbitration fees applies only in cases where the employer imposes mandatory arbitration as a condition of employment which is not the case here.  Arbitration was never a condition of Plaintiff’s employment because, as the agreement states, Plaintiff could have opted out of the agreement.  Further, paragraph 9 in the Arbitration Agreement requires Plaintiff and Defendant to mutually agree on selecting the neutral arbitrator and the rules the arbitrator may use.  (Fimreite Dec., Exh. A, ¶ 9.)  The only limit is that neither party can unilaterally choose JAMS or AAA’s rules absent a mutual agreement.  (Ibid.)  Additionally, paragraph 9, footnote 3 lists several entities from which the parties can find a neutral arbitrator.  (Fimreite Dec., Exh. A, ¶ 9 fn. 3.)

 

Arbitration agreements which cover only those disputes an employee may bring against an employer are considered unfairly “one-sided” and substantively unconscionable.  (Navas v. Fresh Venture Foods, LLC (2022) 85 Cal.App.5th 626, 636.)  However, if the agreement contains broad language that includes any and all claims arising between the parties, and includes a subset of specific claims, the agreement is not substantively unconscionable.  (Baltazar v. Forever 21, Inc. (2016) 62 Cal.4th 1237, 1248-49; Prostek v. Lincare, Inc. (E.D. Cal. 2023) 662 F.Supp.3d 1100, 1122.)

 

In Prostek v. Lincare, Inc., the trial court held that a “covered claims” provision was not “one-sided” because the provision was broad and expressly contained a non-exclusive and illustrative list of covered claims.  (Prostek, supra, 662 F.Supp.3d at p. 1120.)  The provision included “all claims and disputes” arising from an employment relationship and listed a subset of employment claims such as failure to pay wages and failure to provide rest or meal periods.  (Ibid.)  The provision also stated that the covered claims were not limited to this illustrative list of potential employment disputes.  (Ibid.)

 

Prostek distinguished the broad language in the arbitration agreement from the agreement at issue in Navas v. Fresh Venture Foods, basing its reasoning in Baltazar v. Forever 21, Inc. (2016) 62 Cal.4th 1237.  The “covered disputes” provision in Baltazar arbitration agreement, which is almost identical to Prostek, covered “any claim or action” arising out of the employment relationship, was not limited to specific employment claims only an employee would bring against an employer, and included a non-exhaustive list of claims only an employee would bring against an employer.  (Id. at p. 1248.)  The Court of Appeal held the provision was not unfairly “one-sided” or substantively unconscionable because the provision covered claims an employer and an employee might bring.  (Id. at p. 1249.)

 

The Arbitration Agreement’s “covered disputes” provision is broader than the provisions in Baltazar and Prostek.  The provision includes “any and all claims, causes of action, or other disputes or controversies that have already accrued, now exist, or arise in the future” between Defendant and Plaintiff “based on any legal, equitable, or other ground or theory.”  (Fimreite Dec., Exh. A, ¶ 3.)  The provision also expressly lists a subset of employment related issues, but this list does not limit the covered disputes to only these issues.  (Ibid.)  Therefore, the Arbitration Agreement is not substantively unconscionable because of the covered disputes provision.

 

Finally, an arbitration agreement may contain an enforceable waiver that waives the right to initiate or participate in a class action.  (Prostek, supra, 662 F.sSupp.3d at p. 1122 [citing AT&T Mobility v. Concepcion (2011) 563 U.S. 333, 351].)  The FAA preempts California law governing when class action waivers in employment arbitration agreements.  (Evenskass v. California Transit, Inc. (2022) 81 Cal.App.5th 285, 297-298.)  Under the FAA, a party cannot be compelled to submit to class arbitration unless there is a contractual basis for concluding that the party agreed to do so.  (Viking River Cruises, Inc. v. Moriana (2022) 596 U.S. 639, 652.)  The Arbitration Agreement waives both Defendant and Plaintiff’s right to bring a class action for any covered disputes.  (Fimreite Dec., Exh. A, ¶ 11.)  This waiver does not contribute to the Arbitration Agreement being unconscionable.

 

Accordingly, the Arbitration Agreement is not procedurally or substantively unconscionable, and the Court grants Defendant’s petition.

 

CONCLUSION

Defendant’s petition to compel arbitration is granted.

 

The case is stayed as to all parties, pending arbitration pursuant to Code of Civil Procedure section 1281.4.

 

Defendant Kohl’s Inc. to give notice.