Judge: Joseph Lipner, Case: 22STCV29951, Date: 2023-10-26 Tentative Ruling

Case Number: 22STCV29951    Hearing Date: November 30, 2023    Dept: 72

 

SUPERIOR COURT OF CALIFORNIA

COUNTY OF LOS ANGELES

 

DEPARTMENT 72

 

TENTATIVE RULING

 

BIANCA BALL,

 

                                  Plaintiff,

 

         v.

 

 

CDC RESTAURANT GROUP, INC.,

 

                                  Defendants.

 

 Case No:  22STCV29951

 

 

 

 

 

 Hearing Date:  November 30, 2023

 Calendar Number:  5

 

 

 

Defendants CDC Restaurant Group, Inc. dba Chick-fil-A Restaurants (“CDC”) and Jeremia Cillpam (collectively, “Defendants”) move the Court for an order compelling Plaintiff Bianca Ball to submit her individual Private Attorney General Act (“PAGA”) claims to binding arbitration and dismissing her non-individual PAGA claims.

 

Defendants’ motion to compel arbitration of Plaintiff’s individual PAGA claims is GRANTED.

 

Defendants’ motion to dismiss the non-individual PAGA claims is DENIED.

 

Defendants’ request for a stay on the non-individual PAGA claims is DENIED.

 

Plaintiff’s request to compel arbitration of the non-individual PAGA claims is DENIED.

 

The Court’s stay on this action is LIFTED as to the non-individual PAGA claims.

 

Background

 

CDC Restaurant Group is a California corporation that owns and operates Chick-fil-A restaurants. Its corporate headquarters is in Hollywood, California.

 

This action arises out of Plaintiff’s employment with CDC as a human resources coordinator from November, 2021 to May, 2022.

 

On September 14, 2022, Plaintiff filed this action under PAGA, alleging violations of Labor Code sections 210; 225.3; 558; 1174.5; 1197.1; and 26.99.

 

Plaintiff alleges that she is an aggrieved employee under PAGA and seeks civil penalties for these Labor Code violations. In particular, Plaintiff alleges that Defendants had policies or practices of failing to pay overtime wages, failing to pay minimum wages for all hours worked, failing to provide meal breaks, failing to provide rest breaks, failing to provide itemized wage statements, failing to pay all wages owed, failing to reimburse employees costs resulting from their duties, failing to provide sick leave, preventing employees from disclosing skills, knowledge, and experience gained while working for Defendants, and preventing employees from engaging in lawful conduct during non-work hours. Plaintiff alleges that she suffered each of these harms and is therefore representative of other aggrieved employees.

 

Defendants filed an answer on December 7, 2022.

 

The action was temporarily stayed so that the parties could participate in mediation. The parties participated in mediation on February 14, 2023.

 

Defendants filed this motion on May 15, 2023. Plaintiff filed an opposition and Defendants filed a reply.

 

On October 26, the Court ordered additional briefing on (1) the effect of Adolph v. Uber Technologies, Inc. (2023) 14 Cal.5th 1104 on the resolution of the motion; (2) whether the Federal Arbitration Act (“FAA”) applies to this case; and (3) if the FAA does not apply, whether the Court should deny the motion as a result. Plaintiff and Defendants both filed additional briefs on these issues.

 

 

Evidentiary Objections

 

Plaintiff objects to a portion of ¶ 3 of the Declaration of Lonnie D. Giamela. The Court is not able to determine the portion objected to, since the first Giamela declaration does not have a third paragraph and the quoted portion of the declaration does not match any portion of ¶ 3in Giamela’s supplemental declaration. The Court therefore overrules the objection. 

 

Plaintiff objects to ¶ 8 of the Declaration of Summer Stearns. The Court overrules the objections. Stearns’ supplemental declaration filed on November 20, 2023 alongside Defendants’ supplemental briefing, and in particular ¶ 3 of that declaration, cures any authentication objection. Given the timing of the most recent filings, if Plaintiff at the hearing asks for an opportunity to submit any evidence or argument in connection with the November 20, 2023 Stearns Declaration, the Court will grant Plaintiff leave to do so.    

 

Legal Standard

 

Applicable Law

         

          As set forth below, the arbitration agreement provides that the parties will settle their disputes according to the California Arbitration Act (“CAA”) except where it conflicts with the goals and policies of the FAA. The agreement also states that it is not intended to preclude the application of the FAA if the FAA would be applicable. The Court finds that this is not a clear statement that the FAA governs enforcement of the arbitration agreement, in contrast with the agreement in Williams v. Eaze Solutions, Inc. (N.D. Cal. 2019) 417 F.Supp.3d 1233, 1238, cited by Defendants, where the agreement stated that “the terms of service state[d] that the ‘Federal Arbitration Act will govern the interpretation and enforcement’ of its dispute resolution provisions[.]” (Ibid.)

 

The FAA provides for enforcement of arbitration provisions in any contract “evidencing a transaction involving [interstate] commerce.” (9 U.S.C. § 2; Nixon v. AmeriHome Mortgage Company, LLC (2021) 67 Cal.App.5th 934, 945.) A transaction involves interstate commerce when it turns out in fact to involve interstate commerce, even if it was not the intent of the parties. (Allied-Bruce Terminix Companies, Inc. v. Dobson (1995) 513 U.S. 265, 277-278.) The party claiming that the contract involves interstate commerce and that the FAA preempts state law has the burden of proof. (Woolls v. Superior Court (2005) 127 Cal.App.4th 197, 211.)

 

Where the FAA applies, it preempts any state rule that either facially or covertly discriminates against arbitration. (9 U.S.C. § 2; Kindred Nursing Centers Ltd. Partnership v. Clark (2017) 581 U.S. 246, 251.)

 

Here, Plaintiff was a resident of California and worked in California for the entirety of her employment with Defendants.

 

Defendant argues that its contracts with its employees necessarily involve interstate commerce because it purchases food and beverages from out of state. Defendant argues that either the scope of the employee’s work or the nature of the employer’s business can disjunctively trigger FAA preemption, and that the nature of the employee’s work is irrelevant. (Carbajal v. CWPSC, Inc. (2016) 245 Cal.App.4th 227, 239, citing Lane v. Francis Capital Management LLC (2014) 224 Cal.App.4th 676, 688.) The Court disagrees with this reading of Carbajal. Carbajal cited to Lane for the proposition that an employer that both fails to present evidence as to the nature of its business and the scope of the employee’s work fails to show that the FAA applies, but it did not reach the inverse conclusion that the nature of a business is independently sufficient to trigger the FAA. (Ibid.) The court went on to contrast Lane and Woolls v. Superior Court (2005) 127 Cal.App.4th 197, 214, where the FAA did not apply because the party asserting preemption failed to “present[ ] any facts to show the instant transaction involved interstate commerce” (Wolls at p. 214) with Shepard v. Edward Mackay Enterprises, Inc. (2007) 148 Cal.App.4th 1092, 1101, which applied the FAA where materials involved in the transaction were manufactured outside of California (Shepard at p. 1101). (Carbajal, supra, at p. 239.) The Carbajal court did not apply the FAA on the basis of the nature of the business alone – it did not apply the FAA at all, finding that, similarly to in Lane, the moving party had not presented evidence about the nature of its business or the employee’s work. (Ibid.) Lane, Wolls, Shepard, and Carbajal, read together, indicate that it is the transaction that is the focus of the analysis, not the general nature of the moving party’s business. Here, Plaintiff was not involved in the purchase, transportation, preparation, or distribution of food. Plaintiff was a human resources coordinator. Thus, even if Defendants’ business purchased food from out of state, that act does not automatically subject all of its employees to the FAA if those particular employees’ roles do not involve that food.

 

Defendants argue that Plaintiff’s role involved communicating with out-of-state parties on a daily basis, which it explains means working with a Georgia brokerage firm called “Decisely” to ensure compliance with the Affordable Care Act and acting as the primary point of contact between CDC employees and a Colorado-based retirement benefits company called “Empower Retirement”. (Supp. Stearns Decl. ¶ 5.) The job description that Stearns refers to in the same paragraph makes no reference to either of these companies or their locations, and there is no other evidence provided that shows that Plaintiff conducted these duties. (Supp. Stearns Decl. ¶ 5, Exh. B.) Based on the very tenuous links to interstate commerce that were found adequate in Shepard, the Court finds that this evidence provided by Defendant is adequate to show that the transaction involved interstate commerce.

 

 

Standard Under the FAA

 

 The party moving to compel arbitration must establish the existence of a written arbitration agreement between the parties. (Code of Civ. Proc., § 1281.2.) “With respect to the moving party's burden to provide evidence of the existence of an agreement to arbitrate, it is generally sufficient for that party to present a copy of the contract to the court. (See Condee v. Longwood Management Corp. (2001) 88 Cal.App.4th 215, 218 (Condee ); see also Cal. Rules of Court, rule 3.1330 [“A petition to compel arbitration or to stay proceedings pursuant to Code of Civil Procedure sections 1281.2 and 1281.4 must state, in addition to other required allegations, the provisions of the written agreement and the paragraph that provides for arbitration. The provisions must be stated verbatim or a copy must be physically or electronically attached to the petition and incorporated by reference”].)

 

Once the party moving to compel arbitration presents proof of the existence of the arbitration agreement, the burden shifts to the party opposing the motion to compel.  The opposing party may present any challenges to the enforcement of the agreement and evidence in support of those challenges. [Citation].” (Baker v. Italian Maple Holdings, LLC (2017) 13 Cal.App.5th 1152, 1160.) 

 

As discussed above, where the FAA applies, it preempts any state rule that either facially or covertly discriminates against arbitration. (9 U.S.C. § 2; Kindred Nursing Centers Ltd. Partnership v. Clark (2017) 581 U.S. 246, 251.)

 

Although the FAA has a policy favoring arbitration, this policy “does not authorize federal courts to invent special, arbitration-preferring procedural rules[;]” rather, the policy is intended “to overrule the judiciary's longstanding refusal to enforce agreements to arbitrate and to place such agreements upon the same footing as other contracts.” (Morgan v. Sundance, Inc. (2022) 596 U.S. 411, 418. “[A]rbitration is a matter of contract and a party cannot be required to submit to arbitration any dispute which he has not agreed so to submit.” (AT & T Technologies, Inc. v. Communications Workers of America (1986) 475 U.S. 643, 648.)

 

 

Discussion

 

The Arbitration Agreement

 

The arbitration agreement which Defendants contend that Plaintiff signed reads, in relevant part, as follows:

 

 

“The parties agree to submit to final and binding arbitration any dispute, controversy or claim that arises from the employment relationship, unless arbitration of the dispute would be prohibited by law. This means that a neutral arbitrator, rather than a court or jury, will decide the dispute. This will be the parties' sole and exclusive remedy.

 

This Agreement extends to all claims relating to Employee's employment and termination of employment, including, but not limited to: Claims for breach of contract or an express or implied covenant of good faith and fair dealing; intentional or negligent infliction of emotional distress; defamation; wrongful termination or constructive discharge; unlawful discrimination or harassment including claims arising under the Fair Employment and Housing Act, the Civil Rights Act of 1964, and the Americans with Disabilities Act; wage and hour claims under state and federal law; claims under the Employee Retirement Income Security Act ("BRISA") and the Consolidated Omnibus Budget Reconciliation Act ("COBRA"); and any allegation of injury to physical, mental or economic interests. This Agreement extends to claims that could be brought in court, or before an administrative body, such as the Labor Commissioner, unless the law compels that such claims be brought before the administrative body. The arbitrator will have authority to determine all issues between the parties, including the validity or enforceability of this Agreement.

 

The parties will settle their dispute(s) according to the provisions of California Arbitration Act ("CAA"), including provisions for discovery, provided that the CAA does not undermine the goals and policies of the Federal Arbitration Act ("FAA"). The parties' designation of the CAA does not preclude the application of the FAA if the FAA would be applicable.”

 

(Stearns Decl. ¶ 8, Exh. H.)

 

Plaintiff contends that she has no recollection of ever being asked to sign an arbitration agreement during her employment. (Ball Decl. ¶ 5.)

 

The two declarations of Summer Stearns, taken together, show that Plaintiff accessed the onboarding platform HigherMe, which contained the arbitration agreement, and digitally executed the arbitration agreement. Accordingly, Defendants have met their burden of showing that Plaintiff was a party to the arbitration agreement.

 

 

Labor Code Section 229

 

“Labor Code section 229 provides that actions ‘for the collection of due and unpaid wages claimed by an individual may be maintained without regard to the existence of any private agreement to arbitrate.’ The FAA preempts Labor Code section 229, requiring enforcement of an arbitration agreement covering such a claim.” Garrido v. Air Liquide Industrial U.S. LP (2015) 241 Cal.App.4th 833, 844–845, quoting Lab. Code § 229 and citing Perry v. Thomas (1987) 482 U.S. 483, 491.) “In contrast, when only the CAA applies, an action under Labor Code section 229 may be maintained in court.” (Id. at p. 845.)

 

Because the FAA applies to the arbitration agreement, Labor Code section 229 is preempted by the FAA.

 

 

Waiver of Arbitration

 

Litigation

 

          Plaintiff argues that Defendants have waived the enforcement of the arbitration agreement by participating in litigation.  The Court disagrees.

 

In order to prove a waiver of the right to arbitrate, a nonmoving party was traditionally required to demonstrate that the moving party (1) was aware of its right to compel arbitration, (2) acted inconsistently with that right, and (3) prejudiced the nonmoving party as a result. (Hoover v. American Income Life Ins. Co. (2012) 206 Cal.App.4th 1193, 1203, citing U.S. v. Park Place Associates, Ltd. (9th Cir. 2009) 563 F.3d 907, 921.) However, the Supreme Court has recently held that “prejudice is not a condition of finding that a party, by litigating too long, waived its right to stay litigation or compel arbitration under the FAA.” (Morgan v. Sundance, Inc. (2022) 596 U.S. 411, 419.)

 

“The relevant factors establishing waiver include whether the party's actions are inconsistent with the right to arbitrate; whether the litigation machinery has been substantially invoked and the parties were well into preparation of a lawsuit before the party notified the opposing party of an intent to arbitrate; whether a party delayed for a long period before seeking a stay; whether important intervening steps [e.g., taking advantage of judicial discovery procedures not available in arbitration] had taken place; and whether the delay affected, misled, or prejudiced the opposing party.” (Hoover, supra, 206 Cal.App.4th at p. 1204.) “[T]he bad faith or willful misconduct of a party may constitute a waiver and thus justify a refusal to compel arbitration.” (Davis v. Blue Cross of Northern California (1979) 25 Cal.3d 418, 426 [internal quotations and citations omitted].)

 

“[A] party may be said to have “waived” its right to arbitrate by an untimely demand, even without intending to give up the remedy. In this context, waiver is more like a forfeiture arising from the nonperformance of a required act.” (Burton v. Cruise (2010) 190 Cal.App.4th 939, 944 [citation omitted].) However, some California appellate courts hold that “a delay is found unreasonable only when it is combined with the attempt by the party asserting a right to arbitrate to obtain an advantageous litigation position during the delay.” (Gloster v. Sonic Automotive, Inc. (2014) 226 Cal.App.4th 438, 449.) “[T]he absence of a reasonable explanation for delay is a significant factor weighing in favor of finding waiver.” (Davis v. Shiekh Shoes, LLC (2022) 84 Cal.App.5th 956, 969.)

 

Defendants were aware of their right to arbitrate because they repeatedly informed Plaintiff of their intent to compel arbitration during the pendency of this matter. (Supp. Giamela Decl. ¶ 3.) Thus, the only analysis remaining is whether Defendants engaged in conduct inconsistent with that right.

 

In Bower v. Inter-Con Security Systems, Inc. (2014) 232 Cal.App.4th 1035, 1044-1049, the moving party attempted to settle the case on a class-wide basis and obtained discovery from the plaintiffs prior to filing a motion to compel arbitration. (Ibid.) The court found that this conduct was inconsistent with the party’s right to arbitrate because it took advantage of discovery, delayed arbitration of the individual claim, and attempted to settle the claim class-wide instead of on an individual basis as compelled by the arbitration agreement. (Id. at 1045.)

 

In Garcia v. Haralambos Beverage Co. (2021) 59 Cal.App.5th 534, 543-545, a moving party acted in a manner inconsistent with its right to arbitrate where it engaged in class-wide mediation, represented in status conference statements that it did not intend to arbitrate, and responded to the plaintiff’s discovery requests and meet and confers. (Ibid.)

 

Conversely, in Gloster v. Sonic Automotive, Inc. (2014) 226 Cal.App.4th 438, 449, the moving parties deferred a motion to compel arbitration while awaiting the results of another defendant’s demurrer, which would have simplified the arbitration motion, and filed the motion four months after the demurrer’s resolution. (Ibid.) The moving parties filed no motions of their own and restricted their litigation activity to responding to discovery and attending case management conferences. (Ibid.) The court found that the moving parties had not waived arbitration. (Id. at 450.)

 

Here, Defendants filed their motion to compel arbitration eight months after the case was filed. During that time, Defendants filed an answer and the parties engaged in mediation. Defendants did not file any other motion in this matter during that time.

 

On October 3, 2022, Defendants sent Plaintiff a meet and confer letter requesting to submit the matter to arbitration. Defendants’ April 4, 2023 Case Management Statement also asserted that Plaintiff’s claims were subject to arbitration.

 

Prior to mediation, Plaintiff’s counsel obtained extensive employment records and data for the putative class from Defendants in what Plaintiff’s counsel refers to as ‘informal discovery.’ (Glitz Decl. ¶ 4.) The parties have not propounded any formal written discovery in this matter. (Supp. Giamelo Decl. ¶ 5.) Plaintiff also contends that Defendant sought and obtained information during that mediation on Plaintiff’s intent to recover damages for all class members in litigation, rather than arbitration. (Glitz Decl. ¶ 7.)

 

The parties engaged in mediation on February 14, 2023. Plaintiff contends that the mediation was aimed at reaching a global resolution of all claims on a class-wide basis. (Glitz Decl. ¶ 6.) Plaintiff also contends that Defendants only changed course and decided to demand arbitration rather than mediating the claims when they discovered that Plaintiff intended to seek damages for all class members in litigation, including those who were alleged to have signed arbitration agreements. (Glitz Decl. ¶ 7.) Defendants contend that Glitz could not have known Defendants’ intention in mediating the matter, but do not deny that an objective of the mediation was to resolve the claims on a class-wide basis. (Supp. Giamela Decl. ¶ 5.)

 

As discussed above, a party’s intent as to actions that may waive arbitration is irrelevant. (Burton, supra, 190 Cal.App.4th at p. 944.) Thus, if Defendants engaged in mediation that in fact concerned the class-wide settlement of the claims, as the record suggests, then that action was inconsistent with an intent to arbitrate the claims regardless of what thoughts Defendants held in their mind while doing so. However, this is the only action that appears inconsistent with intent to arbitrate. Unlike in Garcia and Bower, Defendants did not engage in formal discovery, either by propounding or responding to it. Furthermore, unlike in Garcia, Defendants repeatedly stated their intent to arbitrate, rather than denying such intent. Finally, as mentioned above, Defendant has not filed any other motions in this case. Thus, the Court finds that the factors to be considered, on balance, do not support a finding of waiver.

 

 

Failure to File a Fictitious Name Statement

 

Plaintiff argues that Defendant waived arbitration by failing to file a fictitious name statement as required by Business & Professions Code section 17910. Plaintiff contends that Defendants operated under the fictitious name of “Chik-fil-A Hollywood” but failed to register the DBA until March of 2023 at the earliest.

 

“[A] party who fails to file a valid statement cannot ‘maintain any action upon or on account of any contract made ... in the fictitious business name in any court of this state until the fictitious business name statement’ has been filed.” (Villareal v. LAD-T, LLC (2022) 84 Cal.App.5th 446, 454 [quoting Bus. & Prof. Code, § 17918].) “Failure to comply with the fictitious-name statutes does not make the parties' promises, agreements, and transactions invalid as such. Noncompliance merely prevents a fictitiously named business from enforcing obligations owed to it until it places on record its true nature and ownership.” (Hydrotech Systems, Ltd. v. Oasis Waterpark (1991) 52 Cal.3d 988, 1001.)

 

Defendants have provided evidence of CDC’s fictitious name notice as to the name “Chik-fil-A Hollywood.” (Stearns Decl. ¶ 3, Ex. B.) Thus, this is not a basis for waiver here.

 

 

PAGA Claims

 

Plaintiff argues that if the FAA applies and Plaintiff is compelled to arbitrate her individual PAGA claims, she should also be permitted to arbitrate the non-individual PAGA claims asserted in the Complaint under the arbitration agreement. Defendants argue that the Court should stay Plaintiff’s non-individual PAGA claims pending arbitration.  Neither option is appropriate.

 

“ PAGA authorizes ‘an aggrieved employee,’ acting as a proxy or agent of the state Labor and Workforce Development Agency (LWDA), to bring a civil action against an employer ‘on behalf of himself or herself and other current or former employees to recover civil penalties for Labor Code violations they have sustained.” (Adolph v. Uber Technologies, Inc. (2023) 14 Cal.5th 1104, 1113, quoting Lab. Code, § 2698.) “Where a plaintiff has brought a PAGA action comprising individual and non-individual claims, an order compelling arbitration of the individual claims does not strip the plaintiff of standing as an aggrieved employee to litigate claims on behalf of other employees under PAGA.” (Id. at 1114.)

 

“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.” (Adolf, supra, 14 Cal.5th at p. 1113.) Settlement of a plaintiff’s individual claims does not nullify their status as an aggrieved employee because “[t]he remedy for a Labor Code violation, through settlement or other means, is distinct from the fact of the violation itself.. (Kim v. Reins International California, Inc. (2020) 9 Cal.5th 73, 84 [emphasis in original].)

 

Adolph is clear that Plaintiff maintains standing to litigate her non-individual claims in court; thus, a stay as requested by Defendants is not proper. The remaining question is whether Plaintiff should be permitted to proceed with her non-individual PAGA claims in arbitration.

 

“Relief under PAGA is designed primarily to benefit the general public, not the party bringing the action.” (Kim, supra, 9 Cal.5th at p. 81.) A PAGA claim for civil penalties is fundamentally a law enforcement action where the government entity on whose behalf the plaintiff files suit is the real party in interest. (Adolph, supra, 14 Cal.5th at p. 1119.) The judgment in a representative PAGA action “is binding not only on the named employee plaintiff but also on government agencies and any aggrieved employee not a party to the proceeding.” (Arias v. Superior Court (2009) 46 Cal.4th 969, 985.) “Because collateral estoppel applies not only against a party to the prior action in which the issue was determined, but also against those for whom the party acted as an agent or proxy, a judgment in an employee's action under the act binds not only that employee but also the state labor law enforcement agencies.” (Id. at p. 986 [internal citations omitted].)

 

The fact that the resolution of Plaintiff’s non-individual claims would collaterally estop the state government and other aggrieved employees, some of whom may not have signed arbitration agreements, is troubling. “Of course, any employee is free to forgo the option of pursuing a PAGA action. But is against public policy for an employment agreement to deprive employees of this option altogether, before any dispute arises.” (Iskanian v. CLS Transportation Los Angeles, LLC (2014) 59 Cal.4th 348, 387, abrogated on other grounds by Viking River Cruises, Inc. v. Moriana (2022) 142 S.Ct. 1906.) Although the course of action Plaintiff suggests here does not technically involve a prospective agreement to arbitrate non-individual claims, it functionally allows Plaintiff and Defendants to bind employees who are not signatories to an arbitration agreement to have their PAGA claims resolved by arbitration instead of by litigation. Those parties are at least as much intended beneficiaries of the PAGA claims as is Plaintiff. Furthermore, there is the issue that ordering arbitration of the non-individual claims would compel Defendants to arbitrate disputes which they had not agreed to arbitrate. Thus, the Court finds that requiring arbitration of the non-individual PAGA claims would run counter to the purpose of PAGA and would likely violate state contract law as well.

 

The Court therefore denies Defendants’ motion to dismiss the non-individual claims, denies Defendants’ request for a stay on the non-individual claims, and denies Plaintiff’s request for an order to compel arbitration of the non-individual claims.