Judge: Mark A. Young, Case: 23SMCV02155, Date: 2023-11-30 Tentative Ruling

Case Number: 23SMCV02155    Hearing Date: November 30, 2023    Dept: M

CASE NAME:           Dooman, et al., v. Tesla Inc.

CASE NO.:                23SMCV02155

MOTION:                  Petition/Motion to Compel Arbitration

HEARING DATE:   11/30/2023

 

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.)

 

Analysis

 

Defendant Tesla, Inc. moves to compel Plaintiffs Koroush Dooman and Elena Semenova’s claims to arbitration in accordance with their arbitration agreement with Tesla, and to stay this action pending the outcome of arbitration.

 

Valid Arbitration Agreement

 

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.”].) 

 

Defendant points to two agreements relating to the Vehicle, both of which contain binding arbitration provisions: (1) the Order Agreement, the terms of which Plaintiffs agreed to when they placed their order for the Vehicle (Kim Decl., Ex. 1), and (2) the Lease, which Plaintiffs signed just prior to delivery (Kim Decl., Ex. 2). The terms of both agreements require arbitration to resolve any “dispute arising out of or relating to any aspect of the relationship between you and Tesla… [including] claims arising before this Agreement, such as claims related to statements about our products.” (Id.) Plaintiffs do not dispute that they signed the Order and Lease Agreements, which contain broad Arbitration clauses applying to the claims at hand. Thus, Defendant meets its burden to show that Plaintiffs signed the Arbitration agreements. Therefore, Plaintiffs have the burden to show a defense to these agreements.

 

Unconscionability

 

Plaintiff argues that the agreement is unconscionable. 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 in the same degree. (Armendariz v. Found Health Psychcare Servs., Inc. (2000) 24 Cal.4th 83, 114.) “Essentially a sliding scale is invoked which disregards the regularity of the procedural process of the contract formation, that creates the terms, in proportion to the greater harshness or unreasonableness of the substantive terms themselves.  [Citations.] 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.) 

 

As to procedural unconscionability, Plaintiffs note that the sales contract was a pre-printed consumer sales contract presented in a "take it or leave it" fashion, and thus they had no meaningful opportunity to negotiate any of the terms. Notably, this agreement is not an employment agreement, thus the adhesive nature of the contract provides little to no procedural unconscionability. (See Baltazar v. Forever 21 Inc. (2016) 62 Cal.4th 1237, 1246; [Courts do not recognize that “adhesive” arbitration agreements in the employment context establish a high degree of procedural unconscionability absent “surprise or other sharp practices”]; see also Nguyen v. Applied Medical Resources Corp. (2016) 4 Cal.App.5th 232, 248; [the fact that an arbitration agreement is presented as a “take-it-or-leave-it” contract of adhesion in the employment context, alone only establishes a modest degree of procedural unconscionability].) However, the record shows that this is not the case. The terms of the Agreements allow a customer to opt out of arbitration agreement by sending a letter within 30 days stating that intention. (Kim Decl. ¶ 7.) Plaintiffs did not do so. (Id.)

 

Plaintiffs also assert that the agreement is procedurally unconscionable because Tesla failed to provide a copy of the relevant arbitration rules or even advise which rules would be chosen. Plaintiff does not demonstrate that a failure to attach arbitration rules, by itself, creates procedural unconscionability. Courts have found that failure to attach arbitration rules to an arbitration agreement requires courts to scrutinize the substantive unconscionability of terms that were “artfully hidden” but does not otherwise add to the procedural unconscionability of the agreement. (E.g., Baltazar, supra, 62 Cal.4th at 1246; Nguyen, supra, 4 Cal.App.5th at 248-249; see also A & M Produce Co. v. FMC Corp., (1982) 135 Cal. App. 3d 473, 483 [limitation on consequential damages in may be unconscionable].) Plaintiff does not point to any such terms, artfully hidden or otherwise.

 

As to substantive unconscionability, an agreement is substantively unconscionable if it imposes terms that are “overly harsh,” “unduly oppressive,” “unreasonably favorable,” or “so one-sided as to ‘shock the conscience.’ ”  (Sanchez v. Valencia Holding Co., LLC (2015) 61 Cal.4th 899, 910-911.) “All of these formulations point to the central idea that unconscionability doctrine is concerned not with ‘a simple old-fashioned bad bargain’ [citation], but with terms that are ‘unreasonably favorable to the more powerful party.’ [Citation.]” (Id. at 911.) “These include ‘terms that impair the integrity of the bargaining process or otherwise contravene the public interest or public policy; terms (usually of an adhesion or boilerplate nature) that attempt to alter in an impermissible manner fundamental duties otherwise imposed by the law, fine-print terms, or provisions that seek to negate the reasonable expectations of the nondrafting party, or unreasonably and unexpectedly harsh terms having to do with price or other central aspects of the transaction.’ ”  (Ibid.)

 

Plaintiffs argue that the clause disallowing Plaintiffs’ choice of arbitrator is unconscionable. Plaintiffs proffer no citable California authority demonstrating that the election of an arbitration agency such as AAA would be unconscionable. (See Milliner v. Bock Evans Fin. Couns., Ltd., (N.D. Cal. 2015) 114 F. Supp. 3d 871, 880 [process for selecting the arbitrator was substantively unconscionable because Defendant had significantly unequal power in the selection the arbitrator, where Defendant would provide a list of three arbitrators from which Plaintiffs could choose].) Accordingly, the Court does not conclude that this adds to any substantive unconscionability.

 

In summary, there is little to no procedural unconscionability, and no substantial unconscionability. Therefore, the Agreements are not unconscionable.

           

Conclusion

 

Defendant meets its burden to demonstrate the existence of an arbitration agreement between the parties that covers Plaintiffs’ claims. Plaintiffs, in turn, fail to demonstrate that the agreement is unconscionable. Defendant’s 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 sets a status conference re arbitration for November 29, 2024, at 8:30 a.m.