Judge: Mark A. Young, Case: 22SMCV00604, Date: 2024-05-08 Tentative Ruling



Case Number: 22SMCV00604    Hearing Date: May 8, 2024    Dept: M

CASE NAME:           Li, v. Jenkins, et al.

CASE NO.:                22SMCV00604

MOTION:                  Petition/Motion to Compel Arbitration

HEARING DATE:   5/8/2024

 

Legal Standard

 

Under California and federal law, public policy favors arbitration as an efficient and less expensive means of resolving private disputes. (Moncharsh v. Heily & Blase (1992) 3 Cal.4th 1, 8-9; AT&T Mobility LLC v. Concepcion (2011) 563 U.S. 333, 339.) Accordingly, whether an agreement is governed by the California Arbitration Act (“CAA”) or the Federal Arbitration Act (“FAA”), courts resolve doubts about an arbitration agreement’s scope in favor of arbitration.  (Moncharsh, supra, 3 Cal.4th at 9; Comedy Club, Inc. v. Improv West Assocs. (9th Cir. 2009) 553 F.3d 1277, 1284; see also Engalla v. Permanente Med. Grp., Inc. (1997) 15 Cal.4th 951, 971-972 [“California law incorporates many of the basic policy objectives contained in the Federal Arbitration Act, including a presumption in favor of arbitrability [citation] and a requirement that an arbitration agreement must be enforced on the basis of state law standards that apply to contracts in general”].) “[U]nder both the FAA and California law, ‘arbitration agreements are valid, irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of any contract.’ ” (Higgins v. Superior Crout (2006) 140 Cal.App.4th 1238, 1247.)

 

            “Code of Civil Procedure section 1281.2 requires a trial court to grant a petition to compel arbitration if the court determines that an agreement to arbitrate the controversy exists.” (Avery v. Integrated Healthcare Holdings, Inc. (2013) 218 Cal.App.4th 50, 59, quotations omitted.) Accordingly, “when presented with a petition to compel arbitration, the court’s first task is to determine whether the parties have in fact agreed to arbitrate the dispute.”  (Ibid.) A petition to compel arbitration is in essence a suit in equity to compel specific performance of a contract. (Id. at 71.) As with any other specific performance claim, “a party seeking to enforce an arbitration agreement must show the agreement’s terms are sufficiently definite to enable the court to know what it is to enforce.” (Ibid. [internal citations omitted].) “Only the valid and binding agreement of the parties, including all material terms well-defined and clearly expressed, may be ordered specifically performed.” (Ibid.) An arbitration agreement “must be so interpreted as to give effect to the mutual intention of the parties as it existed at the time of contracting, so far as the same is ascertainable and lawful.” (Civ. Code, § 1636.) The language of the contract governs its interpretation if it is clear and explicit. (Civ. Code, § 1368.) If uncertainty exists, “the language of a contract should be interpreted most strongly against the party who caused the uncertainty to exist.” (Civ. Code, § 1654.)

 

            The party seeking to compel arbitration bears the burden of proving the existence of a valid arbitration agreement by the preponderance of the evidence. (Engalla v. Permanente Medical Group, Inc. (1997) 15 Cal.4th 951, 972.) It would then be plaintiff’s burden, in opposing the motion, to prove by a preponderance of the evidence any fact necessary to her opposition. (See Ibid.) “In these summary proceedings, the trial court sits as a trier of fact, weighing all the affidavits, declarations, and other documentary evidence, as well as oral testimony received at the court’s discretion, to reach a final determination.” (Ibid.)

 

Analysis

 

Defendants Bongo LLC, Jeff Jenkins Productions, LLC, and Jeff Jenkins move to arbitrate Plaintiff Kelly Li’s claims. Defendants assert that the instant claims must be arbitrated because Plaintiff signed an arbitration agreement covering her claims. Based upon the papers, there is no dispute that Plaintiff’s claims are subject to a valid arbitration clause. Plaintiff only argues that Defendants have waived their contractual right to arbitrate through their litigation efforts in this action.

 

Waiver

 

“California courts have found a waiver of the right to demand arbitration in a variety of contexts, ranging from situations in which the party seeking to compel arbitration has previously taken steps inconsistent with an intent to invoke arbitration [citations] to instances in which the petitioning party has unreasonably delayed in undertaking the procedure. [Citations.] The decisions likewise hold that the ‘bad faith’ or ‘wilful misconduct’ of a party may constitute a waiver and thus justify a refusal to compel arbitration. [Citations.]” (Engalla v. Kaiser Permanente Medical Group, Inc. (1997) 15 Cal.4th 951, 983, quoting Davis v. Blue Cross of Northern California (1979) 25 Cal.3d 418.) 

 

“Whether a party to an arbitration agreement has waived the right to arbitrate is a question of fact, and a trial court’s determination on that matter will not be disturbed on appeal if supported by substantial evidence . . .. Since arbitration is a strongly favored means of resolving disputes, courts must ‘closely scrutinize any claims of waiver.’” (Sobremonte v. Superior Court (1998) 61 Cal. App. 4th 980, 991 [citations omitted].) “No single test delineates the nature of the conduct that will constitute a waiver of arbitration.” (St. Agnes Medical Center v. PacifiCare of California (2003) 31 Cal. 4th 1187, 1195.) “In determining waiver, a court can consider (1) whether the party’s actions are inconsistent with the right to arbitrate; (2) 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; (3) whether a party either requested arbitration enforcement close to the trial date or delayed for a long period before seeking a stay; (4) whether a defendant seeking arbitration filed a counterclaim without asking for a stay of the proceedings; (5) whether important intervening steps [e.g., taking advantage of judicial discovery procedures not available in arbitration] had taken place; and (6) whether the delay affected, misled, or prejudiced the opposing party.” (Sobremonte, supra, 61 Cal. App. 4th at 992 [citation omitted].)

 

Plaintiff filed this lawsuit on April 28, 2022. On June 2, 2022, Defendants answered and asserted arbitration as an affirmative defense. Rather than immediately filing this motion, Defendants filed a timely special motion to strike under Code of Civil Procedure section 425.16 (the “Anti-SLAPP"). The Court denied the Anti-SLAPP on December 16, 2022. Defendants timely appealed the Anti-SLAPP ruling on January 17, 2023. The court of appeal affirmed the anti-SLAPP ruling. The Court received the remittitur on November 15, 2023. Defendants moved for arbitration on January 31, 2024.

 

Plaintiff argues that this constitutes a twenty-one-month delay in prosecuting this case. However, the Court would not count that entire time period against Defendants. First, Defendants immediately notified Plaintiff of their arbitration defense in their June 2, 2022, answer. Second, the action was stayed upon appeal of the anti-SLAPP ruling from January 17, 2023, through November 15, 2023. This time would generally be excluded from calculating how long the suit has been pending and should also be excluded from this time computation. Defendant filed this motion approximately two and a half months later, on January 31, 2024. At worst, Defendant delayed in bringing this motion by about ten months—from June 2, 2022, through January 17, 2023; and from November 15, 2023, through January 31, 2024.

 

Plaintiff only cites an anti-SLAPP motion as unavailable in arbitration. The Court would not view filing an anti-SLAPP alone as substantially invoking litigation machinery, unfairly seeking relief unavailable at arbitration, or fundamentally incompatible with the right to arbitrate. Arbitration and anti-SLAPP motions both promote similar policies of effective and quick resolution of claims. (See Newport Harbor Ventures, LLC v. Morris Cerullo World Evangelism (2018) 4 Cal.5th 637 [the purpose of the Anti-SLAPP statute is to resolve cases early and efficiently].) Anti-SLAPP motions must be made within 60 days after the filing of the targeted complaint. (Id.) No cited authority found a waiver of an arbitration provision from a 60 day delay. Counsel may not have the opportunity to obtain the relevant arbitration agreement, meet and confer with opposing counsel regarding their willingness to arbitrate, and draft a motion to arbitrate within that short time period. If the Court required an arbitration motion to be made prior to an anti-SLAPP motion, the Court would undermine the purpose of the anti-SLAPP statute to resolve meritless claims before substantial litigation occurs.

 

The Court notes that no trial date is set. Plaintiff has not cited any other litigation efforts undertaken, including discovery that would be unavailable at arbitration. Defendants have sought no counter claims against Plaintiff. Critically, Plaintiff also cites no prejudice stemming from the anti-SLAPP or the delay caused thereby. Plaintiff only notes that they have had to expend fees litigating the action, which is not the type of prejudice required for waiver. (See St. Agnes Med. Ctr. v. PacifiCare of California (2003) 31 Cal. 4th 1187, 1203 [“merely participating in litigation, by itself, does not result in a waiver, courts will not find prejudice where the party opposing arbitration shows only that it incurred court costs and legal expenses”].) Otherwise, Plaintiff only cites the delay itself as the prejudice, which is a circular argument.

 

Accordingly, Defendants’ motion is GRANTED and the Court orders Plaintiff’s claims to arbitration, as discussed above. The entire action is STAYED pending the completion of the arbitration. (CCP § 1281.4.)  The Court will set a status conference re arbitration for April 3, 2025 at 8:30 a.m.