Judge: Mark A. Young, Case: 23SMCV01714, Date: 2023-09-19 Tentative Ruling

Case Number: 23SMCV01714    Hearing Date: September 19, 2023    Dept: M

CASE NAME:           Hartman v. Avantstay Inc., et al.

CASE NO.:                23SMCV01714

MOTION:                  Petition/Motion to Compel Arbitration

HEARING DATE:   9/20/2023

 

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.)

 

EVIDENTIARY ISSUES

 

Plaintiff’s evidentiary objections are OVERRULED.

 

Analysis

 

Valid Arbitration Agreement

 

            Defendants assert that the instant claims are required to be arbitrated because Plaintiff signed an arbitration agreement covering her claims.  As with any contract, mutual assent or consent is necessary for the formation of a valid arbitration agreement. (Civ. Code, §§ 1550, 1565.) “Consent is not mutual, unless the parties all agree upon the same thing in the same sense.” (Civ. Code, § 1580.) The moving party bears the initial burden of showing the existence of an agreement to arbitrate by a preponderance of the evidence. (Mitri v. Arnel Mgmt. Co. (2007) 157 Cal.App.4th 1164, 1169 [“Because the existence of the agreement is a statutory prerequisite to granting the petition, the petitioner bears the burden of proving its existence by a preponderance of the evidence.”].) 

 

On March 22, 2022, Plaintiff executed a PEO Arbitration Agreement and AvantStay’s Arbitration and Equitable Relief Agreement (hereinafter, the “Arbitration Agreements”) through which she agreed that both she and AvantStay would submit to binding arbitration of any and all claims arising out of her employment. Specifically:

 

By signing the PEO Arbitration Agreement, Jennifer Hartman (“Worksite Employee”), on the one hand, and AvantStay, Inc. (“Worksite Employer”). . . on the other hand, agree to use binding arbitration as the sole and exclusive means to resolve all disputes that may arise between Worksite Employee and Worksite Employer and/or Worksite Employee and PEO, including, but not limited to, disputes regarding termination of employment and compensation. Worksite Employee specifically waives and relinquishes Worksite Employee’s right to bring a claim against Worksite Employer and/or PEO, in a court of law, and this waiver shall be equally binding on any person who represents or seeks to represent Worksite Employee in a lawsuit against Worksite Employer or PEO in a court of law. Similarly, Worksite Employer and PEO specifically waive and relinquish their respective rights to bring a claim against Worksite Employee in a court of law, and this waiver shall be equally binding on any person who represents or seeks to represent Worksite Employer or PEO in a lawsuit against Worksite Employee in a court of law.

 

(Kreitler Decl. at ¶ 7, Exhibit C.)

 

There is no reasonable dispute that the claims fall under the scope of the broad arbitration provision set forth above. Plaintiff’s complaint against Defendants makes claims solely related to her employment with Defendants. This above clause would apply to the claims at hand.

 

In addition, Plaintiff challenges the authenticity of the electronic signature on the Agreements. Under the Uniform Electronic Transactions Act, an electronic signature “is attributable to a person if it was the act of the person. The act of the person may be shown in any manner, including a showing of the efficacy of any security procedure applied to determine the person to which the electronic record or electronic signature was attributable.” (Civ. Code, § 1633.9(a).) The effect of such electronic signature “is determined from the context and surrounding circumstances at the time of its creation, execution, or adoption, including the parties’ agreement.” (Civ. Code, § 1633.9(b).)

 

Caselaw describes the security precautions necessary to show that that an electronic signature is attributable to a person under the UETA. In Ruiz v. Moss Bros. Auto Group, Inc. (2014) 232 Cal.App.4th 836, the declaration seeking to authenticate the plaintiff’s electronic signature on an arbitration agreement was deemed insufficient where the declarant “summarily asserted” plaintiff electronically signed the agreement and “did not explain how she arrived at that conclusion or inferred [plaintiff] was the person who electronically signed the agreement” or that the electronic signature “was ‘the act’” of the plaintiff. (Ruiz 232 Cal.App.4th at 844-845.) A supplemental declaration, generally explaining the onboarding process, failed to explain that: all Moss Brothers employees were required to use their unique login ID and password when they logged into the HR system and signed electronic forms and agreements; how an electronic signature in the name of “Ernesto Zamora Ruiz” could only have been placed on the 2011 agreement by a person using Ruiz's “unique login ID and password”; or, how the declarant otherwise ascertained how Ruiz's printed electronic signature came to be placed on the 2011 agreement. (Id., at 845.) The court concluded that in “the face of Ruiz's failure to recall electronically signing the 2011 agreement, the fact the 2011 agreement had an electronic signature on it in the name of Ruiz, and a date and time stamp for the signature, was insufficient to support a finding that the electronic signature was, in fact, ‘the act of’ Ruiz.” (Id.)

 

By contrast, in Espejo v. Southern California Permanente Medical Group (2016) 246 Cal.App.4th 1047, the “declaration offered the critical factual connection that the declarations in Ruiz lacked,” by detailing “security precautions regarding transmission and use of an applicant’s unique username and password, as well as the steps an applicant would have to take to place his or her name on the signature line” of the agreement. (Espejo, 246 Cal.App.4th at 1062.) The declarant, Tellez, specifically stated:

 

once the “Area Medical Director decides to make a physician an offer of employment, [the director] completes the employment agreement, and electronically signs the agreement, an email is generated to the applicant” with a link to the SCPMG Applicant Homepage. Access to the applicant homepage “requires the use of a private and unique username and password,” both of which are provided by phone “directly and orally to the applicant.” After logging into SCPMG's online system with this username and password, “the first thing Dr. Espejo would be required to do is re-set his password to one of his own choosing. He cannot proceed to the next page unless he re-sets his password.” At that point, according to Tellez, Espejo would have to “opt to agree to complete the employment documents using an electronic signature.” Once he agreed, he would be directed to the portion of the Applicant Homepage containing the four hyperlinks to his employment agreement, the DRP, the R&R, and a benefits handbook. “Dr. Espejo only had access to these documents by logging in and using his unique user name and password.”

 

…On the signature page of the employment agreement Dr. Espejo was prompted to either accept or decline the employment agreement.” If he accepted, “he was prompted to complete his name as he would sign it. Whatever name he typed into this entry is what populated on the signature line of the contract.” “Once that information was input and accepted by Dr. Espejo, then the employment agreement was finalized, including his name, date, time, and the IP address where Dr. Espejo electronically signed the agreement.” Tellez then outlined the same process with respect to the DRP. She stated that the “name Jay Baniaga Espejo could have only been placed on the signature pages of the employment agreement and the DRP by someone using Dr. Espejo's unique user name and password.... [¶] Given this process for signing documents and protecting the privacy of the information with unique and private user names and passwords, the electronic signature was made by Dr. Espejo” to the employment agreement and the DRP at the date, time, and IP address listed on the documents. Tellez therefore concluded that the copies of the employee agreement and the DRP attached to defendants' petition were true and correct copies of the documents “electronically signed by Dr. Espejo on May 22, 2011, and kept and maintained in SCPMG's records.”

 

(Id. at 1053-1054.)

 

Defendants provide a declaration which demonstrates sufficient authentication of the onboarding process to demonstrate that the electronic signature was the act of Plaintiff. (Kreitler Decl., ¶¶ 2-6.) This includes a description of the on-boarding process, where the employee is sent a link sent to their email address, and the employee creates a “Rippling account” with a unique username and password. (Id. ¶ 5.) Only after creating an account and logging in with the user’s unique credentials, the user can access and view the onboarding documents supplied to them by their employer or prospective employer. (Id.) Rippling PEO’s Worksite Employee Acknowledgement and PEO Arbitration Agreement were made available to Plaintiff via her individual online portal account on March 17, 2022, and executed by Ms. Hartman on March 22, 2022. (Id. ¶ 7.) The Rippling PEO online portal data shows that Hartman executed both Rippling PEO’s Worksite Employee Acknowledgement and PEO Arbitration Agreement on March 22, 2022. (Id. ¶ 8.)

 

Plaintiff’s own evidence admits that Plaintiff, in fact, signed the agreements in question. Plaintiff explains that when she began employment with Defendant, Defendant requested that she review and sign a series of onboarding documents online. (Hartman Decl. ¶ 3.) On March 17, 2022, Plaintiff opened the onboarding documents on her computer. (Hartman Decl. ¶ 3.) As Plaintiff scrolled through the onboarding documents, she noticed an arbitration agreement. (Hartman Decl. ¶ 3.) The arbitration agreement appeared to offer two options, to either agree to, or to opt out of, the arbitration agreement. (Hartman Decl. ¶ 3.) Plaintiff would never have agreed to arbitration, so she intended to select the “opt out” option. (Hartman Decl. ¶ 3.) Plaintiff did not click any button or option to agree to or sign an arbitration agreement. (Hartman Decl. ¶ 3.) However, the software would not allow her to check the “opt out” button because the space for opting out was not accessible. (Hartman Decl. ¶ 3.) Instead, the accept option was preselected and Plaintiff was not permitted to undo it. (Hartman Decl. ¶ 3.) Hartman’s intention was that after she completed the onboarding documents, she would contact her supervisor to confirm she was opting out of the arbitration agreement. (Hartman Decl. ¶ 3.) However, she never completed the onboarding paperwork because the system froze completely when she accidentally clicked “no” in response to a prompt to allow access to her device for purposes of uploading a picture of herself for the Company. (Hartman Decl. ¶ 3.) When the system froze on Hartman, rendering it impossible to complete her onboarding documents, she tried to log out and back in, and cleared her internet cache to try to regain access to her onboarding documents. (Hartman Decl. ¶ 4.) These attempts to access and complete the onboarding documents were unsuccessful and the system would not allow Hartman to complete the onboarding documents or to see or review any documents. (Hartman Decl. ¶ 4.) Hartman could not review documents she previously reviewed and could not review any potential documents beyond the documents she reviewed. (Hartman Decl. ¶ 4.)

 

Hartman contacted her supervisor, Yael Livneh, to explain that she was unable to complete the onboarding documents because the system glitched. (Hartman Decl., ¶ 5.) Plaintiff specifically mentioned the arbitration agreement and told Livneh she wanted to opt out but that there was no way to select the opt out box. (Hartman Decl., ¶ 5.) Livneh advised her to submit a tech support ticket, which she did. (Id.) However, she never heard back from anyone from tech support, the issue was never resolved, and she never completed the paperwork. (Id.) On March 23, 2022, she discussed these issues with Ms. Livneh, including her intent to opt out of the Arbitration Agreement because the opt out option was not available the only time she was able to access the onboarding documents. (Id. ¶6.)

 

In effect, Plaintiff admits that the signature on the Agreements is her signature, but that her signature is on the agreement because the program would not allow her to opt out. This further separates this case from Ruiz, where the plaintiff averred that he was unable to recall signing the agreement. Here, Plaintiff admits to electronically signing an arbitration agreement, just that she did not actually intend to agree to arbitrate. While there is some unfairness in leading an employee to believe that they could opt out of an arbitration agreement, but precluding them from doing so, the take-it-or-leave-it nature of the instant arbitration agreement would not negate the fact that Plaintiff, indeed, signed the Agreements. Thus, the totality of the evidence suggests Plaintiff agreed to the arbitration agreements. Further, Plaintiff was provided notice that there was an arbitration agreement attendant to her employment. When an employee continues her employment after notification that an agreement to arbitration is a condition of employment, that employee has impliedly consented to the arbitration agreement. (Diaz v. Sohnen Enterprises (2019) 34 Cal.App.5th 126, 130) Thus, even if Plaintiff did not wish to agree to the arbitration agreement, she still accepted employment knowing that she had signed the agreement. Plaintiff has not presented persuasive evidence that she expressed her intent not to arbitrate.

 

Accordingly, Defendants meet their burden to demonstrate the existence of an arbitration agreement between the parties that covers Plaintiff’s claims. The motion is therefore 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 in approximately nine months.