Judge: Michael Shultz, Case: 22STCV05884, Date: 2023-04-25 Tentative Ruling

Case Number: 22STCV05884    Hearing Date: April 25, 2023    Dept: A

22STCV05884 Jane Doe v. Healthcare Career College, Alex Arviso

Tuesday, April 25, 2023 at 8:30 a.m.

 

[TENTATIVE] ORDER GRANTING MOTION TO COMPEL ARBITRATION AND STAYING THE ACTION

I.        BACKGROUND

 

The complaint alleges that Plaintiff was a student of Alex Arviso (“Arviso”) at Healthcare Career College when she was sexually assaulted by Arviso. Plaintiff alleges claims for assault, battery, intentional infliction of emotional distress, negligent hiring and retention, and for negligence.

            The Court initially heard this matter on March 14, 2023, and continued the hearing at defense counsel’s request.

 

I.        ARGUMENTS

            Defendant, Infotech Institute, Inc., dba Healthcare Career College (“Infotech” or “Defendant”), requests an order compelling Plaintiff to submit the claims to binding arbitration pursuant to the parties’ agreement. The agreement is enforceable and applies to any dispute against Infotech as well as its employees.

            In opposition, Plaintiff argues that under federal law, the arbitration agreement is voidable at Plaintiff’s election because the complaint involves sexual assault. Plaintiff denies that she signed the purported arbitration agreement, and Defendant did not prove that Plaintiff electronically signed it. The delegation clause in the agreement is not enforceable and it is unconscionable. Defendant waived its right to arbitrate.

            In reply, Defendant argues that the recently enacted federal statute on which Plaintiff relies does not apply because Plaintiff’s dispute arose prior to the statute’s enactment. The arbitration agreement is authenticated and admissible. Defendant raised arbitration as an affirmative defense and did not waive the right to compel it.

            The Court has considered the supplemental declaration of Amita Garg in support of the motion filed on March 13, 2023.  

 

II.      LEGAL STANDARDS

            The court “shall” compel arbitration if it determines that an agreement to arbitrate the controversy exists, unless the right to arbitration has been waived or there are grounds for rescission of the agreement. (Code Civ. Proc., § 1281.2.) The petitioner’s burden is to establish that a valid arbitration agreement exists. The opposing party’s burden is to establish a defense to enforcement based on a preponderance of evidence.  (Molecular Analytical Systems v. Ciphergen Biosystems, Inc. (2010) 186 Cal.App.4th 696, 705.)

            Defendant’s burden in moving to compel arbitration is to show the existence of an agreement, not its validity.  (Espejo v. Southern California Permanente Medical Group (2016) 246 Cal.App.4th 1047, 1058 ["as a preliminary matter the [trial] court is only required to make a finding of the agreement's existence, not an evidentiary determination of its validity.”]). To meet its burden, the moving party need only attach a copy of the agreement to the petition and incorporate it by reference. (Id. at 1058; Cal. Rules of Court, rule 3.1330 [“The provisions must be stated verbatim or a copy must be physically or electronically attached to the petition and incorporated by reference."].) Therefore, all of Plaintiff’s objections to the Declaration of Armita Garg are OVERRULED.

III.    DISCUSSION

A.      Plaintiff did not establish that federal law bars arbitration of this action.

            Plaintiff’s reliance on 9 U.S.C., section 402 is misplaced. That statute provides that a pre-dispute arbitration agreement is not enforceable if a person alleges conduct constituting sexual harassment or sexual assault. (9 U.S.C.A. § 402 (West)). The statute applies to any dispute or claim that arises or accrues on or after the date of its enactment. (PL 117-90, March 3, 2022, 136 Stat 26). Plaintiff’s claims arose on July 1, 2020, when she alleged the sexual assault took place. (Complaint, ¶ 2).

 

B.      Defendant has established that the electronic signature on the agreement is attributable to Plaintiff.

            Amita Garg, Defendant’s Chief Executive Officer and Campus President, attests to Defendant’s use of an application called “signNow” which requires students to create a unique login and password to facilitate electronic signatures. (Garg Supp. Decl. ¶ 2). Plaintiff declares that she signed “a bunch of papers” given to her by her admissions officer. (Decl. of Jane Doe, ¶ 8). She declares she never signed an arbitration agreement, nor did she see one in the papers she was directed to sign. (Doe decl, ¶¶ 9-11).

            Where electronic signatures are involved, Defendant is required to authenticate Plaintiff’s signature since Plaintiff denies signing the agreement. (See Ruiz v. Moss Bros. Auto Group, Inc. (2014) 232 Cal.App.4th 836, 844).  Defendant can attribute the signature to Plaintiff by showing 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 an electronic signature attributed to a person "is determined from the context and surrounding circumstances at the time of its creation, execution, or adoption, including the parties' agreement, if any, and otherwise as provided by law." (Civ. Code, § 1633.9, (b)).

            A party can establish that the electronic signature was the act of Plaintiff “by presenting evidence that a unique login and password known only to that person was required to affix the electronic signature, along with evidence detailing the procedures the person had to follow to electronically sign the document and the accompanying security precautions.” (Bannister v. Marinidence Opco, LLC (2021) 64 Cal.App.5th 541, 545; Ruiz, supra at  844 [where the court of appeal found a “critical gap in the evidence” to infer that the electronic signature was in fact the employee’s without evidence to show that only the employee could have affixed the electronic signature.].)

            Ms. Garg provides the electronic time stamps showing Plaintiff accessed “signNow” through her Gmail account and signed the arbitration agreement on July 30. Garg Suppl. Decl., Ex. B.

C.      Plaintiff has not established that the arbitration agreement is unconscionable.

            There are two elements for determining whether an agreement is unconscionable. There must be evidence of “procedural unconscionability” – namely that circumstances of oppression or surprise due to unequal bargaining power exist. The second element involves “substantive unconscionability,” defined as the presence of overly harsh, one-sided terms. Both elements must be present in order for the Court to exercise its discretion to refuse to enforce the arbitration provision. (De La Torre v. CashCall, Inc. (2018) 5 Cal.5th 966, 982. The Court examines the entire bargaining process and the degree to which each element exists. No one term of the contract determines its application. Rather, Plaintiff must establish the factual context to determine whether both elements exist. (Id. 982-983.)

      The second element, substantive unconscionability, requires a determination that the terms are overly harsh or one sided. More precisely, “substantive unconscionability examines the fairness of a contract's terms. This analysis ‘ensures that contracts, particularly contracts of adhesion, do not impose terms that have been variously described as ‘overly harsh’ [citation], ‘unduly oppressive’ [citation], so one-sided as to ‘shock the conscience’ [citation], or ‘unfairly one-sided’ [citation]. All of these formulations point to the central idea that the 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.” (Prima Donna Development Corp. v. Wells Fargo Bank, N.A. (2019) 42 Cal.App.5th 22, 38.)

      Plaintiff argues that the clause delegating disputes to arbitration demonstrates that it was a contract of adhesion as it was “apparently presented” on a “take it or leave it basis.” Plaintiff refers to an “Uber” contract which is not relevant here. (Opp. 10:18:23.) Regardless, Plaintiff’s declaration does not account for the circumstances in which she was given the arbitration agreement. Plaintiff declares she signed “a bunch of papers,” she did not see the arbitration agreement, and upon information and belief, she never signed it. (Decl. of Jane Doe, ¶ 8-11.) Procedural unconscionability “focuses on the oppression that arises from unequal bargaining power and the surprise to the weaker party that results from hidden terms or the lack of informed choice.” (Ajamian v. CantorCO2e, L.P. (2012) 203 Cal.App.4th 771, 795.) There is no evidence that the arbitration agreement itself was “hidden.”

      Nor has Plaintiff established that the arbitration agreement is “overly harsh” or so “one-sided” as to “shock the conscience.” The agreement states that arbitration will be conducted by a neutral arbitrator with the American Arbitration Association. (Garg Supp. Decl., Ex. B, ¶ 2). Defendant agrees to pay fees incurred to file an arbitration, the arbitrator’s compensation, and facilities fees in excess of the Court filing fee. (Id. ¶ 2.) Plaintiff is not deprived of a neutral arbitrator, which was held "essential to ensuring the integrity of the arbitration process.” (Armendariz at 103.)

D.     Plaintiff has not established that there is a risk of inconsistent rulings if the Court ordered this case to arbitration against Defendant Infotech.

            While Plaintiff also named (but did not serve) Alex Arviso as a defendant, the scope of the arbitration agreement includes disputes against Defendant, “or any of its parents, subsidiaries, officers, directors, or employees, without limitation, … .” (Garg Supp. Decl., Ex. B, ¶ 1.) Therefore, there is no risk of inconsistent rulings.

            Additionally, the agreement provides that the case is to be decided pursuant to the Federal Arbitration Act (“FAA”) and under California law. (Garg Supp. Decl., ¶ 1.) Under state law, when a party to an arbitration agreement is also a party to a pending court action with a third party, and there is a possibility of conflicting rulings on a common issue of law or fact, “the court has several options. It may refuse to compel arbitration, or it may stay either the arbitration or the court proceeding pending completion of the proceedings in the other forum. (Code Civ. Proc., § 1281.2, subd. (c) (section 1281.2(c).)

            However, under the Federal Arbitration Act, title 9 United States Code section 1 et seq. (“FAA”), the court's only option in these circumstances is to stay the court proceeding and compel the arbitration. (Rodriguez v. American Technologies, Inc. (2006) 136 Cal.App.4th 1110, 1114-1115.)

E.      Plaintiff has not established that Defendant waived its right to arbitrate.

            The burden of establishing waiver is a heavy one and “rests on the party seeking to establish waiver which ‘is not to be lightly inferred.’” (Christensen v. Dewor Developments (1983) 33 Cal.3d 778, 782.) Plaintiff does not cite any applicable authority that Defendant’s “delay” in filing this motion three months after the complaint was filed constitutes a waiver of the right to arbitration.

            There is no single test to determine whether waiver has occurred.  (St. Agnes Medical Center v. PacifiCare of California (2003) 31 Cal.4th 1187, 1195.) The Court considers a number of factors including “(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.” (Id. at 1196.)

            Defendant asserted the right to arbitrate as a 53rd affirmative defense. (1st Am. Answer). Plaintiff does not proffer any evidence that Infotech acted in a manner inconsistent with the right to arbitrate, such as obtaining Plaintiff’s discovery responses. Nor has Plaintiff established how the purported delay alone caused prejudice to Plaintiff. “Mere participation” in litigation does not result in waiver; “there must be 'judicial litigation of the merits of arbitrable issues.” (Christensen v. Dewor Developments (1983) 33 Cal.3d 778, 782.)

            Finally, Plaintiff requests a continuance of the hearing to present evidence regarding the “commercial setting, purpose, and effect” of the contract or provision. (Cal Civ Code § 1670.5).. The Court has discretion to afford the parties a reasonable opportunity to prevent evidence where it appears that the contract or clause “may” be unconscionable. (Id.) The Court has considered Plaintiff’s arguments regarding unconscionability, which is not supported by any evidence. Plaintiff could have attested to the circumstances that created an oppressive environment but did not. Plaintiff did not establish that the agreement itself is harsh or one-sided. Nor has Plaintiff explained what evidence, assuming any exists, would warrant a different conclusion.              

 

IV.                CONCLUSION 

         Based on the foregoing, Defendant’s Motion to Compel Arbitration is GRANTED. This action is stayed pending completion of arbitration. The Court sets an Order to Show Cause Re: Status of Arbitration for October 9, at 8:45 a.m. in Department A of the Compton courthouse