Judge: Lee W. Tsao, Case: 23NWCV02576, Date: 2024-07-10 Tentative Ruling

Case Number: 23NWCV02576    Hearing Date: July 10, 2024    Dept: C

MANCILLA v. HYUNDAI MOTOR AMERICA

CASE NO.:  23NWCV02576

HEARING:  7/10/24

 

#3

TENTATIVE ORDER

 

Defendant Hyundai Motor America’s motion to compel arbitration is GRANTED.

 

Moving Party to give NOTICE.

 

 

This is a Song-Beverly action. Defendant Hyundai Motor America moves to compel arbitration of the parties’ dispute about alleged violations of the Song-Beverly Act.

 

Requests for Judicial Notice

 

Plaintiff requests judicial notice of the following: (1) Martha Ochoa v. Ford Motor Company (2023) 89 Cal.App.5th 1324; (2) Mark Kielar v. Super. Ct. (2023) 94 Cal.App.5th 614; (3) Ngo v. BMW of North America, LLC, et al. (9th Cir. 2002) 23 F.4th 942.

 

The Court grants judicial notice under Evidence Code section 451, subdivision (a).

 

Compel Arbitration

 

Defendant moves to compel arbitration on the grounds of equitable estoppel. Defendant argues that because Plaintiff agreed to be bound by a Retail Installment Sale Contract (“RISC”) requiring him to resolve any disputes concerning the purchase or condition of the vehicle by binding arbitration, he must arbitrate his dispute with Defendant. Defendant also moves to arbitrate based on the arbitration provision as part of Plaintiff’s warranty.

 

          Retail Installment Sales Contract

 

A nonsignatory manufacturer can compel arbitration under equitable estoppel “when the causes of action against the nonsignatory are ‘intimately founded in and intertwined’ with the underlying contract obligations.” (Felisilda v. FCA US LLC (Felisilda) (2020) 53 Cal.App.5th 486, 495.) The causes of actions are intimately founded in and intertwined even if they do not exclusively rely on the contract terms. “ ‘The fundamental point’ is that a party is ‘not entitled to

make use of [a contract containing an arbitration clause] as long as it worked to [his or] her advantage, then attempt to avoid its application in defining the forum in which [his or] her dispute . . . should be resolved.’” (Id. at 496.)

 

The court in Felisilda, supra, 53 Cal.App.5th 486, 496-497, held that the manufacturer could compel arbitration because the condition of the vehicle was within the subject matter of the claims made arbitrable under the sale contract, the sale contract was the source of the manufacturer’s warranties under which plaintiffs were suing, and plaintiffs had expressly agreed to arbitrate claims arising out of the condition of the vehicle, even against third party nonsignatories.

 

The court in Ford Motor Warranty Cases (2023) 89 Cal.App.5th 1324, disagreed with Felisilda that arbitration could be compelled under an identical arbitration provision. This Court can now choose to either continue to follow Felisilda or instead adopt Ford’s reasoning. (Sarti v. Salt Creek Ltd. (2008) 167 Cal.App.4th 1187, 1193.)

 

The Ford court disagreed with Felisilda on the grounds that the fact “[t]hat the Felisilda plaintiffs and the dealers agreed in their sale contract to arbitrate disputes between them about the condition of the vehicle does not equitably estop the plaintiffs from asserting [the manufacturer] has no right to demand arbitration. Equitable estoppel would apply if the plaintiffs had sued [the

manufacturer] based on the terms of the sale contract yet denied [the manufacturer] could enforce the arbitration clause in that contract.” (Ford, supra, 89 Cal.App.5th 1324, 1334.) The Ford court held that the plaintiffs’ claims did not arise in the sale contracts and instead on the statutory obligations under the Song-Beverly Consumer Warranty Act, breach of implied warranty of merchantability, and fraudulent inducement. “Not one of the plaintiffs sued on any

express contractual language in the sale contract.” (Ford, supra, 89 Cal.App.5th 1324, 1335.)

 

Specifically, the contract contained provisions that disclaimed any warranty by the Dealers, “while acknowledging no effect on ‘any warranties covering the vehicle that the vehicle manufacturer may provide.’” (Ibid.) Further, the California Supreme Court distinguished between warranties from the seller arising out of contract and warranties from the manufacturer arising “independently of a contract of sale between the parties.” (Greenman v. Yuba Power

Products, Inc. (1963) 59 Cal.2d 57, 60.) Thus, plaintiffs’ claims were not “intimately founded in and intertwined” with the sale contracts because the sale contracts do not intend to cover the manufacturer’s warranties. (Ford, supra, 89 Cal.App.5th 1324, 1336.) Therefore, equitable estoppel does not apply to compel plaintiff to arbitrate his claims because plaintiff was not making use of the terms of the sale contracts. (Ibid.) This Court chooses to follow Ford’s

reasoning.

 

Defendant cannot compel arbitration because Plaintiff’s claims arise from Defendant’s statutory obligation and are not based on any express contractual language. Equitable estoppel is applicable where one party relies on a contract, which includes an arbitration provision, in asserting its claims against a third party but attempts to avoid its application to determining the forum in pursuing its claims. (Felisilda, supra, 53 Cal.App.5th 486, 496.) Here, like in Ford, Plaintiff’s claims “are based on [Defendant’s] statutory obligations to reimburse consumers or replace their vehicles when unable to repair in accordance with its warranty,” not based “on any express contractual language in the sale contracts.” (Ford, supra, 89 Cal.App.5th 1324, 1335.) Plaintiff’s claims do not arise directly out of the RISC, even if Defendant’s warranties accompanied the sale of the subject vehicle. “The sale contracts include no warranty, nor any assurance regarding the quality of the vehicle sold, nor any promise of repairs or other remedies in the event problems arise. To the contrary, the sale contracts disclaim any warranty on the part of the dealers, while acknowledging no effect on ‘any warranties covering the vehicle that the vehicle manufacturer may provide.’ In short, the substantive terms of the sale contracts relate to sale and financing and nothing more.” (Ibid.) Similarly, here the RISC includes no warranty, any assurance regarding the quality of the vehicle, no promise to make repairs, and disclaims any manufacturer warranty. Thus, like Ford, Plaintiff’s claims arise from Defendant’s statutory obligation and not from the sale contract. Therefore, Defendant may not compel arbitration because Plaintiffs’ claims are not intimately found in or intertwined with the RISC.

 

          Warranty

 

Plaintiff argues that the arbitration clause in the warranty is procedurally and substantively unconscionable.

 

A showing of unconscionability requires procedural and substantive unconscionability. Procedural unconscionability asks whether there is oppression from unequal bargaining power or surprise from buried terms. (Armendariz v. Foundation Health (2000) 24 Cal.4th 83, 114.) Substantive unconscionability asks whether there are overly harsh, one-sided terms. (Id.) Both are required to be proven to find unconscionability. However, there is a sliding scale; if an agreement is particularly substantively unconscionable, the petitioner need not show a large amount of procedural unconscionability, and vice versa. (Id.) “The party resisting arbitration bears the burden of proving unconscionability.” (Pinnacle Museum Tower Assn. v. Pinnacle Market Development (US), LLC (2012) 55 Cal.4th 223, 236.)

 

                   Procedural Unconscionability

 

Plaintiff bears the burden of proving, by a preponderance of the evidence, any fact necessary to show the Agreement was invalid. (See Banner Entertainment, Inc. v. Super. Ct.¿(1998) 62 Cal.App.4th 348, 356-357.)

 

Plaintiff argues that the arbitration agreement was not disclosed to Plaintiff, it was buried in the warranty booklet, and he never signed the agreement. But these circumstances, alone, do not constitute procedural unconscionability. (See Dougherty v. Roseville Heritage Partners (2020) 47 Cal.App.5th 93, 103.) Unlike the plaintiff in Dougherty, the plaintiff had options and could have purchased the vehicle elsewhere.  

 

                   Substantive Unconscionability

 

Plaintiff makes no arguments about substantive unconscionability.

 

Hence, the motion to compel arbitration is GRANTED.