Judge: Ronald F. Frank, Case: 23TRCV02233, Date: 2024-04-04 Tentative Ruling

Case Number: 23TRCV02233    Hearing Date: April 4, 2024    Dept: 8

Tentative Ruling¿ 

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HEARING DATE:                 April 4, 2024 

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CASE NUMBER:                   23TRCV02233

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CASE NAME:                        Setareh Nazarian; Jabbar Nazarian v. American Honda Motor Co., Inc. 

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MOVING PARTY:                 (1) Defendant, American Honda Motor Co., Inc. 

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RESPONDING PARTY:        (1) Plaintiff, Setareh Nazarian and Jabbar Nazarian

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TRIAL DATE:                        Not Set.   

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MOTION:¿                              (1) Motion to Compel Arbitration 

                                                (2)  CMC

 

Tentative Rulings:                  (1) GRANTED; civil case is stayed pending further order of the Court

                                                (2) CMC is mooted but the Court will set an arbitration status conference for February 6, 2025, at 8:30 a.m.

 

 

 

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I. BACKGROUND¿¿ 

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A. Factual¿¿ 

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On September 21, 2023, Plaintiffs, Daniel Wei and Natalie Wei (collectively “Plaintiffs”) filed a Complaint against Defendants, American Honda Motor Co., Inc, and DOES 1 through 10. The Complaint alleges causes of action for: ” (1) Violation of Civil Code § 1793.2(d); (2) Violation of Civil Code § 1793.2(b); (3) Violation of Civil Code § 1793.2(a)(3); and (4) Breach of the Implied Warranty of Merchantability – Civil Code §§ 1791.1, 1794; 1795.5.

 

The Complaint is based on a January 25, 2021 lease by Plaintiffs of a 2020 Honda Civic with corresponding identification number VIN: 2HGFC2F60LH525084 (hereafter "Vehicle") from Scott Robinson Honda. Plaintiffs further note that the causes of action contained in his complaint arise out of warranty and repair obligations of Honda. (Complaint, ¶ 10.) Plaintiffs contend that the defects and nonconformities to warranty manifested themselves within the applicable express warranty period, and include, but are not limited to: climate control defects, electrical defects, infotainment defects, body defects, and other defects and nonconformities. (Complaint, ¶ 11.)

 

            Defendant, American Honda Motor Co., Inc. (“AHM”) now files a Motion to Compel Binding Arbitration.

 

 

 

B. Procedural¿¿ 

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On March 8, 2024, AHM filed a Motion to Compel Arbitration. On March 21, 2024, Plaintiffs filed an opposition. To date, no opposition has been filed. 

 

II. REQUEST FOR JUDICIAL NOTICE

 

            With its moving papers, AHM requested this Court take judicial notice of the following documents:

 

1.     Complaint for Violation of Statutory Obligations, filed in the Los Angeles Superior Court by Plaintiffs SETAREH NAZARIAN AND JABBAR NAZARIAN on July 11, 2023, in the matter of Setareh Nazarian And Jabbar Nazarian v. American Honda Motor Company, Inc. (Case No. 23TRCV02233) (Exhibit 1.)

2.     Notice of Entry of Dismissal and Proof of Service, filed in Sacramento Superior Court by plaintiffs Dina C. Felisilda and Pastor O. Felisilda on February 11, 2016, in the matter of Dina C. Felisilda, et al. v. FCA US LLC, et al. (Case No. 34-2015-00183668).(Exhibit 2.)

3.     Defendant American Honda Motor Co., Inc.’s Answer to Complaint, filed in the Los Angeles Superior Court on August 14, 2023, in the matter of Setareh Nazarian And Jabbar Nazarian v. American Honda Motor Company, Inc. (Case No. 23TRCV02233). (Exhibit 3.)

 

The Court GRANTS this request and takes judicial notice of the above documents.

 

With the opposition papers, Plaintiffs request this Court take judicial notice of the following documents:

 

1.     Ford Motor Warranty Cases (Cal. Ct. App. Apr. 4, 2023) 89 Cal.App.5th 1324 (“Ochoa v. Ford”), review granted, (Exhibit A.)

2.     Rosanna Montemayor et al. v. Ford Motor Company, 92 Cal.App.5th 958 (Cal. Ct. App. June 26, 2023) (“Montemayor”), review granted. (Exhibit B.)

3.     Kielar v. The Superior Court of Placer County, 94 Cal.App. 5th 614 (Cal. Ct. App. August 16, 2023) (“Kielar”), review granted, (Exhibit C.)

4.     California Court of Appeal, Third Appellate District’s August 28, 2023 Response to Petition for Writ of Mandate in Campos et al. v. The Superior Court of Butte County, No. C098848. (Exhibit D.)

5.     California Court of Appeal, Third Appellate District’s August 28, 2023 Response to Petition for Writ of Mandate in Ortiz et al. v. The Superior Court of Sacramento County, No. C099135. (Exhibit E.)

6.     Yeh v. Superior Ct. of Contra Costa Cnty., 95 Cal.App.5th 264 (Cal. Ct. App. Sept. 6, 2023) (“Yeh”), review granted. (Exhibit F.)

 

The Court also GRANTS this request and takes judicial notice of the above documents.

 

 

 

III. ANALYSIS

 

A.    Legal Standard

 

The purpose of the Federal Arbitration Act (“FAA”) is “to move the parties in an arbitrable dispute out of court and into arbitration as quickly and easily as possible.”¿ (Moses H. Cone Memorial Hosp. v. Mercury Constr. Corp. (1983) 460 U.S. 1, 23.)¿ California Code of Civil Procedure, Section 1281 provides that “[a] written agreement to submit to arbitration an existing controversy or a controversy thereafter arising is valid, enforceable, and irrevocable, save upon such grounds as exist for the revocation of any contract.”¿ “California law, like federal law, favors enforcement of valid arbitration agreements.”¿ (Armendariz v. Foundation Health Psychcare Services, Inc. (2000) 24 Cal.4th 83, 97.)¿ “On petition of a party to an arbitration agreement alleging the existence of a written agreement to arbitrate a controversy and that a party to the agreement refuses to arbitrate that controversy, the court shall order the petitioner and the respondent to arbitrate the controversy” unless grounds exist not to compel arbitration.¿ (Code Civ. Proc. § 1281.2.) The Song-Beverly Act also favors arbitration of Lemon Law disputes with a series of “carrot and stick” provisions that immunize a warrantors from a species of civil penalty if, like Defendant Honda, they have a certified lemon arbitration program in place.

 

Here, the analysis is somewhat different because AHM is a nonsignatory to the agreement, although one of its authorized dealers is a signatory to the agreement upon which AHM’s motion rests, and Plaintiff is a party to that same arbitration agreement.

 

B.    Discussion

 

a.     Existence of Arbitration Agreement

 

Here, the parties agree that there was a written agreement, the Lease Agreement, that included an arbitration agreement. However, as noted in Plaintiffs’ opposition, that agreement is between Plaintiff and Penske Honda Ontario, the dealership. Plaintiffs also note that they brought this case against Honda based on its breach of its statutory obligations under the Song-Beverly Act and the express warranty it gave on the subject vehicle. The portions of the arbitration agreement in the Lease Agreement state, in pertinent part, as follows:

 

15. ARBITRATION. The parties agree that any unresolved disputes shall be submitted to arbitration in accordance with the Arbitration clause (Section 52). By initialing this Section, I am confirming that I have read this Section and the Arbitration clause, including the method of opting out of arbitration. (Id., at p. 3, bold in original.)

 

52. ARBITRATION:  PLEASE READ THIS ARBITRATION PROVISION CAREFULLY TO UNDERSTAND YOUR RIGHTS. BY ELECTING ARBITRATION, YOU AGREE THAT ANY CLAIM THAT YOU MAY HAVE IN THE FUTURE MUST BE RESOLVED THROUGH BINDING ARBITRATION. YOU WAIVE THE RIGHT TO HAVE YOUR DISPUTE HEARD IN COURT AND WAIVE THE RIGHT TO BRING CLASS CLAIMS. YOU UNDERSTAND THAT DISCOVERY AND APPEAL RIGHTS ARE MORE LIMITED IN ARBITRATION

 

Defendant, AHM, also notes that the Arbitration Provision then states the following:

 

Arbitration is a method of resolving a claim, dispute or controversy without filing a lawsuit. By agreeing to arbitrate, the right to go to court is waived and instead claims, disputes or controversies are submitted to binding arbitration. This provision sets forth the terms and conditions of our agreement…

 

By signing the Arbitration Consent, YOU elect to have disputes resolved by arbitration. YOU, HONDA, or any involved third party may pursue a Claim. “Claim” means any dispute between YOU, HONDA, or any involved third party relating to your account, this Lease, or our relationship, including any application, the Vehicle, its performance and any representations, omissions or warranties.

 

(Declaration of Jeanette C. Suarez (“Suarex Decl.”), ¶ 2, Exhibit A, Lease Contract.)

 

            Here, the Court finds that AHM has met its initial burden in establishing the existence of an arbitration agreement. Under Cal. Rules of Court, Rule 3.1330, Defendant only needs to allege the existence of an arbitration agreement and provide the written agreement or state verbatim the provision that provides for arbitration. (See Condee v. Longwood Management Corp. (2001) 88 Cal.App.4th 215, 218-19 [“[Cal. Rules Court, Rule 3.1330] does not require the petitioner to introduce the agreement into evidence or provide the court with anything more than a copy or recitation of its terms. Petitioner need only allege the existence of an agreement and support the allegation as provided in [Cal. Rules Court, Rule, Rule 3.1330].”].)

 

            Thus, the burden now shifts to Plaintiffs to establish that an arbitration agreement does not exist, to demonstrate that the subject arbitration provision cannot be interpreted to require arbitration of the dispute, or to provide evidence establishing a defense to the arbitration agreement.

 

b.     Equitable Estoppel

 

Here, AHM first argues that it can enforce the arbitration provision under the doctrine of Equitable Estoppel. Generally, only parties to a contract containing an arbitration agreement may enforce that arbitration clause. (Thomas v. Westlake (2012) 204 Cal.App.4th 605, 613.) There are exceptions to the general rule. Under one such exception, the doctrine of equitable estoppel, a nonsignatory defendant may move to enforce an arbitration clause. (JSM Tuscany, LLC v. Superior Court (2011) 193 Cal.App.4th 1222, 1236.) AHM’s motion relies on Felisilda and the First District’s reasoning on the equitable estoppel exception to the non-signatory rule. However, there has been a recent conflict in the Courts of Appeal in Lemon Law litigation as to the enforceability of an arbitration agreement by a non-signatory manufacturer to the dealer’s contract containing the arbitration provision. On April 4, 2023, the Second District Court of Appeal declined to follow Felisilda in its decision of Martha Ochoa v. Ford Motor Company (2023) 89 Cal.App.5th 1324. The Court notes that on July 19, 2023, the Supreme Court of California granted review of Ochoa and instructed that California Rules of Court, Rule 8.1115(e)(3) applies. However, the Supreme Court clarified that the Second District’s opinion may be cited to, “not only for its persuasive value, but also for the limited purpose of establishing the existence of a conflict in authority that would in turn allow trial courts to exercise discretion under Auto Equity Sales, Inc. v. Superior Court (1962) 57 Cal.2d 450, 456, to choose between sides of any such conflict.” This Court is exercising its discretion to follow Ochoa rather than Felislida as the better-reasoned appellate decision bearing on the equitable estoppel exception.

 

AHM argues that Plaintiffs are bound to arbitrate by equitable estoppel because their claims are “intimately founded in and intertwined” with the lease contract because Plaintiff alleges that all causes of action are based on the performance and warranties of the vehicle he acquired through the lease contract.

 

“Inextricable Intertwined with the Underlying Contract”

 

            As noted above, AHM argues that Plaintiff is bound by the doctrine of equitable estoppel to arbitrate because his Song-Beverly claims are intimately founded in and intertwined with the obligations of the Lease Agreement giving rise to his claims. AHM argues that Plaintiffs read the arbitration provision containing functionally identical language as the Felisilda plaintiff’s arbitration provision and expressly agreed to arbitrate claims arising out of the lease, and/or condition of the vehicle, including any claims against third party non-signatories. Based on this, AHM contends that pursuant to the express terms of the lease agreement, which accounts for third parties such as AHM, Plaintiff’s claims against it should be resolved through binding arbitration.

 

            To be sure, this case presents facts akin to Felisilda. For example, the arbitration agreements have similar language, the plaintiffs causes of action are very similar, and the charging allegations of the complaints are similar. However, the facts here are also very similar to those presented in Ochoa. The Ochoa court disagreed with Felisilda because the Felisilda plaintiffs and the dealer agreed in their sale contract to arbitrate disputes between them about the condition of the vehicle but did not expressly or impliedly agree to arbitrate disputes under the consumer protection statutes governing manufacturer warranties as distinct from promises or warranties made in the sales contract with the dealer. Ochoa noted that equitable estoppel would apply if the plaintiffs had sued FCA based on the terms of the sale. But that was not the gravamen of the Lemon Law suit in Felisilda, Ochoa, or here. Like the plaintiffs in Felisilda and in Ochoa, Plaintiff here predicates the suit on Honda’s claimed breach of its statutory duties and for breach of the express and implied warranties, not based on plaintiff’s lease agreement with the dealer.

 

Here, AHM argues that Plaintiff signed a contract that bound Plaintiff to arbitration against third party non-signatories. Such language was also present in the contracts at issue in Felisilda and Ochoa. The Court in Ochoa disagreed with the Felisilda court’s interpretation of the sales contract as broadly calling for arbitration of any claims concerning the condition of the vehicle “against third party nonsignatories,” and instead noted that it did not read that language as consent by the purchaser to arbitrate any or all claims with third-party nonsignatories. Rather, the Ochoa Court read it as a further delineation of the subject matter of claims the purchasers and dealers agreed to arbitrate, noting the purchaser(s) agreed to arbitrate disputes “between” themselves—“you and us”— arising out of or relating to “relationship[s],” including “relationship[s] with third parties who [did] not sign th[e] [sale] contract[s],” resulting from the “purchase, or condition of th[e] vehicle, [or] th[e] [sale] contract.” The Ochoa Court further noted that the “third-party” language in the arbitration clause means that if a purchaser asserts a claim against the dealer (or its employees, agents, successors or assigns) that relates to one of these third-party transactions (such as electing to buy insurance, theft protection, extended warranties, and the like), the dealer can elect to arbitrate that claim. The Second District found that such language says nothing of binding the purchaser to arbitrate with the universe of unnamed third parties. IF Plaintiff had sued the individual owners or sales personnel at the leasing dealership regarding fraud in the inducement of the sale, or refusal to perform services listed on the Due Bill, or for leasing a vehicle with scratches on the paint finish (i.e., the condition of the vehicle) that were not visible at the time of retail delivery, or for failure to obtain a promised insurance binder, such third-party claims would be arbitrable. But that is not what Plaintiff here is claiming.

 

            AHM’s warranty, by itself, and without the inclusion of the definition of “HONDA” including AHM, would not be intertwined with the leasing agreement. Song-Beverly claims are not intimately founded in the leasing agreement. AHM and its dealer are separate entities. The warranty and the leasing agreement are separate legal documents, neither of which refer to or incorporate each other. Most automotive manufacturers prohibit their authorized dealers from binding the manufacturer to warranties. Applying Ochoa to this case, the Arbitration Agreement present in Plaintiffs’ leasing agreement does not, by itself and without the inclusion of the definition of “HONDA” including AHM, bind them to arbitrate non-lease agreement issues with AHM. While a Lemon Law case arguably is related to the “condition” of the vehicle sold via the Leasing Contract/Financing Agreement, the gravamen of Plaintiffs’ suit here is not as to the condition of the vehicle at the time of sale, but rather as to subsequent events that manifest only after Plaintiffs drove the vehicle off the lot, later experienced malfunctions or defect, and unsuccessfully sought to have those post-sale matters remedied within a reasonable number of repair attempts.

 

            However, as briefly mentioned above, and as described in detail below, the Arbitration Agreement includes a definition of “HONDA” which is defined in the Lease Contract to include AHM. As such, despite the similarities of Felisilda and Ochoa, this Arbitration Agreement includes a key difference by including AHM in the very definition of “HONDA.”  In the Court’s view, that factual difference is most applicable to the third party beneficiary exception discussed below. 

 

c.      Third-Party Beneficiary

 

AHM argues that it can compel arbitration as a third-party beneficiary to the arbitration provision. “ ‘A third party beneficiary is someone who may enforce a contract because the contract is made expressly for his benefit.’ ” (Jensen v. U-Haul Co. of California (2017) 18 Cal.App.5th 295, 301, 226 Cal.Rptr.3d 797; see also Civ. Code, § 1559 [“[a] contract, made expressly for the benefit of a third person, may be enforced by him ....”].) A person “only incidentally or remotely benefited” from a contract is not a third-party beneficiary. (Lucas v. Hamm (1961) 56 Cal.2d 583, 590, 15 Cal.Rptr. 821, 364 P.2d 685.) Thus, “the ‘mere fact that a contract results in benefits to a third party does not render that party a “third party beneficiary.” (Jensen, at p. 302, 226 Cal.Rptr.3d 797.) Nor does knowledge that the third party may benefit from the contract suffice. (Goonewardene v. ADP, LLC (2019) 6 Cal.5th 817, 830, 243 Cal.Rptr.3d 299, 434 P.3d 124 (Goonewardene).) Rather, the parties to the contract must have intended the third party to benefit.

 

In order for a third party to show that the contracting parties intended to benefit it, under the express terms of the contract at issue and any other relevant circumstances under which the contract was made, “(1) “the third party would in fact benefit from the contract”; (2) “a motivating purpose of the contracting parties was to provide a benefit to the third party”; and (3) permitting the third party to enforce the contract “is consistent with the objectives of the contract and the reasonable expectations of the contracting parties.” (Ochoa, citing Goonewardene, supra, 6 Cal.5th at p. 830.) Here, AHM argues that it is a member of the class of persons for whose benefit the contract was made. The terms of the lease expressly define “HONDA” to include:

 

HONDA means Lessor, Dealer, Honda Lease Trust, American Honda Finance Corporation (AHFC), American Honda Motor Co., Inc., Honda Finance Exchange, Inc., Acura Financial Services (AFS), Honda Financial Services (HFS), HVT, Inc., their parents, subsidiaries, predecessors, successors, assignees, and officers, employees, representatives and agents. YOU means Lessee and Co-Lessee to this Lease.

 

(Suarez Decl., ¶ 2, Exhibit A, Least Contract, p. 6.)

 

Here, this Court notes that in circumstances in which the manufacturer is not defined in the arbitration agreement, and the manufacturer has brough a motion claiming they are a third party beneficiary because of language similar to: “[a]ny claim or dispute . . . which arises out of or relates to . . . any resulting transaction or relationship (including any such relationship with third parties who do not sign this contract,” this this Court will not find that the manufacture is manifested as “including any such relationship with third parties who do not sign this contract.” This is because the Court in of Martha Ochoa v. Ford Motor Company (2023) 89 Cal.App.5th 1324, noted that that allowing a manufacturer to enforce the arbitration provision as a third party beneficiary would be inconsistent with the “reasonable expectations of the contracting parties” where they twice specifically vested the right of enforcement in the purchaser and the dealer only. The Court also notes the Ninth Circuit Court of Appeal’s decision of Ngo v. BMW of North America (9th Cir. 2022) 23 F.4th 943. As noted by the Second District, federal authority is not binding on this court.   In Ngo, the Ninth Circuit Court found that BMW could not enforce the arbitration provision because the clause, which is identical to the one at issue, was strictly limited to the dealership and the Plaintiff, but not BMW. (See Ngo, supra, at p. 948.) As such, BMW was not a party to the agreement, and its obligations to the Ngo family arose independently of the plaintiff’s agreement with the dealership. (Id. at 949.) The Second District analyzed Ngo at length, ultimately reaching the conclusion that the Sales Contract in Ochoa did not benefit a vehicle manufacturer under Goonewardene for three fundamental reasons that the Court need not recite here.

 

            However, this contract in this case, did not merely state a clause like: “[a]ny claim or dispute . . . which arises out of or relates to . . . any resulting transaction or relationship (including any such relationship with third parties who do not sign this contract.” Instead, included in the definition of HONDA, was AHM. As such, this Court finds that Defendant AHM has shown that although it is a nonsignatory of the lease agreement, the inclusion of AHM in the arbitration clause would benefit defendant by allowing these claims to be resolved by arbitration. Further, the inclusion of AHM as a party who may pursue a claim in arbitration shows that the parties, or at least the leasing dealer by including AHM as a party to be benefitted by its inclusion in the scope of intended parties, indeed provide a benefit to AHM. Lastly, under the arbitration clause AHM would have also been able to pursue a claim through arbitration. Therefore, despite arguments made in Plaintiffs’ opposition, this Court finds that all three elements are met, and the defendant is an expressly intended third party beneficiary.  The Court finds that permitting AHM to enforce the contract is consistent with the objectives of the contract and the reasonable expectations of the contracting parties, at least the expectations of those who read the language of the arbitration agreement. 

 

            But Plaintiff contends he did not expect to arbitrate Lemon Law claims and certainly did not expect or intend to arbitrate against AHM, which was not a signatory to nor party to the arbitration agreement.  That raises the unconscionability issue, discussed below.  As an aside, the Court notes that Plaintiff did not expect or intend to have any need to bring a Lemon Law suit, much less expect or intend what forum any such dispute would be litigated in.  But such is the nature of many terms and conditions of contracts that parties sign without carefully reading, including such terms as forum selection, choice of law, and similar “boilerplate” provisions. 

C.    Unconscionability

Plaintiffs next argue that in their opposition that the contract drafted to include AHM is unconscionable.  Unconscionability is a valid defense to a petition to compel arbitration. (Sonic-Calabasas A, Inc. v. Moreno (2013) 57 Cal.4th 1109, 1143.) State law governs the “unconscionability” defense. (Doctor’s Assocs., Inc. v. Casarotto (1996) 517 US 681, 687.) The core concern of the unconscionability doctrine is the “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, supra, 57 Cal.4th at 1145.) The unconscionability doctrine ensures that contracts—particularly contracts of adhesion—do not impose terms that have been variously described as overly harsh, unduly oppressive, so one-sided as to shock the conscience, or unfairly one-sided. (Id.)  Here, Plaintiffs have not identified any overly harsh or unduly oppressive provisions, other than depriving them of the court system to resolve their dispute without any other option.  The Court finds that such a deprivation, without much more, is no overly harsh, unduly oppressive, nor shocking of the conscience. 

“The procedural element of unconscionability focuses on whether the contract is one of adhesion. (Armendariz, supra, 24 Cal.4th at p. 113; Mercuro v. Superior Court, supra, 96 Cal.App.4th at p. 174.) Procedural unconscionability focuses on whether there is “oppression” arising from an inequality of bargaining power or “surprise” arising from buried terms in a complex printed form. (Armendariz, supra, 24 Cal.4th at p. 114; Mercuro v. Superior Court, supra, 96 Cal.App.4th at p. 174.) The substantive element addresses the existence of overly harsh or one-sided terms. (Little v. Auto Stiegler, Inc. (2003) 29 Cal.4th 1064, 1071 [130 Cal.Rptr.2d 892, 63 P.3d 979]; Armendariz, supra, 24 Cal.4th at p. 114.) An agreement to arbitrate is unenforceable only if both the procedural and substantive elements are satisfied. (Armendariz, supra, 24 Cal.4th at p. 113; Mercuro v. Superior Court, supra, 96 Cal.App.4th at p. 174.) However, Armendariz held, “[T]he more substantively oppressive the contract term, the less evidence of procedural unconscionability is required to come to the conclusion that the term is unenforceable, and vice versa.” (Armendariz, at p. 114; see also Kinney v. United HealthCare Services, Inc., supra, 70 Cal.App.4th at p. 1329.).” McManus v. CIBC World Markets Corp. (2003) 109 Cal.App.4th 76, 87.)

 

Procedural Unconscionability

 

            Plaintiffs argue that the arbitration agreement are adhesive and therefore procedurally unconscionable. Plaintiffs base their arguments on the fact that contract is presented as a ‘take it or leave it’ without any opportunity to negotiate its harshly one-sided terms. Further, Plaintiffs argue that the full definition of “HONDA” was only later defined what entities comprised the term, and that the arbitration provision itself is attenuated with small fine print. Here, the Court disagrees. The Arbitration Agreement appears to be on the last page, is in the same size type as the rest of the agreement, and is in fact, bolded more so than other provisions on the page. Further, when there is no other indication of oppression other than the adhesive aspect of an agreement, the degree of procedural unconscionability is low. (Serpa v. California Surety Investigations, Inc. (2013) 215 Cal.App.4th 695, 704.) 

 

            As such, this Court find that the procedural unconscionability is low. 

 

Substantive Unconscionability

 

            Next, Plaintiffs argue that the arbitration agreement is substantively unconscionable because it is devoid of mutuality as AHM is not bound to arbitrate any claims against Plaintiffs. The Court does not find that this – alone – is enough to find substantive unconscionability. What Plaintiffs fail to acknowledge is that while AHM may not be bound to arbitrating claims against Plaintiffs, the terms of the arbitration, if chosen by the parties, apply equally to both sides. An arbitration agreement is generally enforceable, if it (1) provides for neutral arbitrators, (2) provides for more than minimal discovery, (3) requires a written award, (4) provides for all of the types of relief that would otherwise be available in court, and (5) does not require the parties to pay unreasonable costs and fees as a condition of access to an arbitration forum. (See Armendariz v. Foundation Health Psychcare Services, Inc. (2000) 24 Cal.4th 83, 102.)

Unlike other arbitration agreements with substantively problematic provisions, the HONDA arbitration agreement does not require Plaintiff to travel to another state to arbitrate, does not apply the law of any state besides California, does not contain its own internal statute of limitations, does not require Plaintiffs to advance the costs of the arbitrator, and does not contain a limitation of remedies provision preventing Plaintiff from obtaining a refund or a civil penalty or their attorneys fees if they prevail.  Those types of provisions where present raise the substantive unconscionability level above the Court’s threshold for finding an arbitration agreement unenforceable.  While this Court has found arbitration agreements in Song-Beverly cases to be unconscionable, such findings have been on a much stronger showing than Plaintiffs have made here.

            On balance, the Court does not find any arguable substantive unconscionability to rise above the low level, and thus the Court finds the overall arbitration agreement enforceable and not unconscionable.

 

IV. CONCLUSION¿¿ 

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            For the foregoing reasons, AHM’s Motion to Compel Arbitration is GRANTED.  AHM is ordered to give notice and to pay its initial fee to the arbitration forum within 30 days.  The Court sets a hearing on an arbitration status conference 10 months out, on February 6, 2024 at 8:30 a.m.  Proceedings in this civil action are stayed until further order of the Court. 

 

 

AHM is ordered to give notice.