Judge: Stephen P. Pfahler, Case: 23STCV24500, Date: 2024-05-20 Tentative Ruling



Case Number: 23STCV24500    Hearing Date: May 20, 2024    Dept: 68

Dept. 68

Date: 5-20-24

Case: 23STCV24500

 

ARBITRATION

 

MOVING PARTY: Defendant, Mercedes-Benz USA, LLC

RESPONDING PARTY: Plaintiff, Noushin Misaghi

 

RELIEF REQUESTED

Motion to Compel Arbitration and Stay Action

 

SUMMARY OF ACTION

Plaintiff either leased or purchased a new 2022 Mercedes-Benz vehicle on an unspecified date. The vehicle suffers from unspecified defects.

 

On October 9, 2023, Plaintiff filed a complaint for Violations Violation of Song-Beverly Act – Breach of Express Warranty, Violation Violation of Song-Beverly Act – Breach of Implied Warranty, Violation Violation of Song-Beverly Act – Section 1793.2, and Violation Violation of Song-Beverly Act Section 1793.22 – Tanner Consumer Protection Act. Mercedes-Benz USA, LLC answered on November 13, 2023.

 

RULING: Denied.

Request for Judicial Notice: Granted.

The court takes judicial notice of the existence of the complaint, but cannot take judicial notice of the content for any truth of the matter asserted.

 

Defendant Mercedes-Benz USA, LLC (Mercedes-Benz) moves to compel arbitration pursuant to the terms of the lease executed at the time of the acquisition of the vehicle. Mercedes-Benz seeks arbitration on grounds that the claims arise from alleged defects with the vehicle. Mercedes-Benz in its role as manufacturer, concedes it was not a signatory party to the agreement, but insists it can enforce the agreement as the party responsible for the warranty provisions under both the terms of the contract as a third party beneficiary and equitable estoppel. Plaintiff in opposition denies any third party beneficiary relationship between the dealership and manufacturer or basis of estoppel. Plaintiff also challenges the agreement as unconscionable. Mercedes-Benz in reply reiterates the enforceability of the arbitration provision. Mercedes-Benz characterizes the warranty as part of the lease contract, and cites to the language in the arbitration agreement as in no way excluding Mercedes-Benz as a party to any arbitration. Mercedes-Benz emphasizes the equitable estoppel and third party beneficiary basis to compel.

 

“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.” (Code Civ. Proc., § 1281.) “On petition of a party to an arbitration agreement alleging the existence of a written agreement to arbitrate a controversy and that a party thereto refuses to arbitrate such controversy, the court shall order the petitioner and the respondent to arbitrate the controversy if it determines that an agreement to arbitrate the controversy exists, unless it determines that: (a) The right to compel arbitration has been waived by the petitioner; or (b) Grounds exist for the revocation of the agreement.” (Code Civ. Proc., § 1281.2.)

 

Mercedes-Benz moves to compel under the Federal Arbitration Act (FAA), as provided in the contract. While the FAA governs the rules for conducting arbitration, barring citation to a case precluding California law, motions to compel arbitration are still governed by California law. (Adolph v. Uber Technologies, Inc. (2023) 14 Cal.5th 1104, 1119; Viking River Cruises, Inc. v. Moriana (2022) 142 S.Ct. 1906; Volt Information Sciences, Inc. v. Board of Trustees of Leland Stanford Junior University (1989) 489 U.S. 468, 477–479; Victrola 89, LLC v. Jaman Properties 8 LLC (2020) 46 Cal.App.5th 337, 346; see AT&T Mobility LLC v. Concepcion (2011) 563 U.S. 333, 341-346.)

 

The law creates a general presumption in favor of arbitration. In a motion to compel arbitration, the moving party must prove by a preponderance of evidence the existence of the arbitration agreement and that the dispute is covered by the agreement. The burden then shifts to the resisting party to prove by a preponderance of evidence a ground for denial (e.g., fraud, unconscionability, etc.). (Rosenthal v. Great Western Fin'l Securities Corp. (1996) 14 Cal.4th 394, 413-414; Hotels Nevada v. L.A. Pacific Ctr., Inc. (2006) 144 Cal.App.4th 754, 758.) Any challenges to the formation of the arbitration agreement should be considered before any order sending the parties to arbitration. The trier of fact weighs all evidence, including affidavits, declarations, documents, and, if applicable, oral testimony to determine whether the action goes to arbitration. (Hotels Nevada v. L.A. Pacific Ctr., Inc., supra, 144 Cal.App.4th at p. 758.)

 

The court finds the declaration of counsel for defendant sufficiently establishes competence in knowledge, and the rightful possession of the lease agreement containing the subject arbitration clause applicable to the subject action. [Declaration of Ali Ameripour, Ex. 2.] The court finds the language of the agreement also clearly applies to the warranties on the vehicle.

 

The court therefore considers the defenses to arbitration. Plaintiff first raises a brief unconscionability argument on grounds of adhesion presentation and unfavorable terms.

 

Unconscionability claims have both a “‘procedural’” and “‘substantive’” element. (Stirlen v. Supercuts, Inc. (1997) 51 Cal.App.4th 1519, 1531.) “‘Procedural unconscionability’” concerns the manner in which the contract was negotiated and the circumstances of the parties at that time. (Kinney v. United HealthCare Services, Inc. (1999) 70 Cal.App.4th 1322, 1329.) “‘The procedural element focuses on two factors: “oppression” and “surprise.”  “Oppression” arises from an inequality of bargaining power which results in no real negotiation and an absence of meaningful choice. “Surprise” involves the extent to which the supposedly agreed-upon terms of the bargain are hidden in the prolix printed form drafted by the party seeking to enforce the disputed terms.’” (Stirlen v. Supercuts, Inc., supra, 51 Cal.App.4th at p. 1532.) “Substantive unconscionability” involves contracts leading to “‘“overly harsh”’” or “‘“one-sided”’” results.’” … “[U]nconscionability turns … on an absence of ‘justification “for it…” [and therefore] must be evaluated as of the time the contract was made.’” (Id. at p. 1532.)

 

 

“The adhesive nature of the [consumer] contract is sufficient to establish some degree of procedural unconscionability. Yet ‘a finding of procedural unconscionability does not mean that a contract will not be enforced, but rather that courts will scrutinize the substantive terms of the contract to ensure they are not manifestly unfair or one-sided.’” (Sanchez v. Valencia Holding Co., LLC (2015) 61 Cal.4th 899, 915.) “In the area of consumer arbitration, the Legislature has addressed costs in a different way. In 2002, shortly after Armendariz was decided, the Legislature enacted Code of Civil Procedure section 1284.3 to address fees and costs in consumer arbitration. Subdivision (a) of section 1284.3 provides that ‘[n]o neutral arbitrator or private arbitration company shall administer a consumer arbitration under any agreement or rule requiring that a consumer who is a party to the arbitration pay the fees and costs incurred by an opposing party if the consumer does not prevail in the arbitration, including, but not limited to, the fees and costs of the arbitrator, provider organization, attorney, or witnesses.’ Most pertinently, section 1284.3, subdivision (b)(1) provides that ‘[a]ll fees and costs charged to or assessed upon a consumer party by a private arbitration company in a consumer arbitration, exclusive of arbitrator fees, shall be waived for an indigent consumer. For the purposes of this section, “indigent consumer” means a person having a gross monthly income that is less than 300 percent of the federal poverty guidelines. Nothing in this section shall affect the ability of a private arbitration company to shift fees that would otherwise be charged or assessed upon a consumer party to a nonconsumer party.’ Subdivision (b)(2) requires the arbitration provider to give notice of the fee waiver provision, and subdivision (b)(3) provides that “[a]ny consumer requesting a waiver of fees or costs may establish his or her eligibility by making a declaration under oath on a form provided to the consumer by the private arbitration company for signature stating his or her monthly income and the number of persons living in his or her household. No private arbitration company may require a consumer to provide any further statement or evidence of indigence.” (Code Civ. Proc., § 1284.3, subd. (b)(2) & (3).)” (Sanchez v. Valencia Holding Co., LLC, supra, 61 Cal.4th at pp. 918–919.)

 

The court finds the circumstances regarding the transaction, including the placement of the arbitration clause itself, and circumstances in the execution of the agreement rendering the lease as a “one sided” transaction insufficiently supports any basis unconscionability to thwart the enforceability of the agreement on this basis. (See Sanchez v. Valencia Holding Co., LLC, supra, 61 Cal.4th at p. 919-921.) Plaintiff lacks any substantive support establishing a material disadvantage due to the adhesion nature of the contract. The court finds no evidence or argument for indigence thereby materially impacting Plaintiff, especially given the presumed contingency basis of representation in the instant action. The court therefore finds no bar of the arbitration agreement on grounds of unconscionability.

 

The court next considers the argument regarding the lack of Mercedes-Benz as a signatory party to the agreement, thereby barring enforcement of the contract. The lease itself provides for the terms, and includes the referenced arbitration clause. The agreement was only between Plaintiff and non-party Keyes European. Mercedes-Benz is not a named party within the agreement. [Ameripour Decl., Ex. 2.]

 

Arbitration agreements may only be generally compelled by parties to the agreement. The doctrine of equitable estoppel allows for a non-signatory party to compel arbitration “‘when the causes of action against the nonsignatory are “intimately founded in and intertwined” with the underlying contract obligations.’” (JSM Tuscany, LLC v. Superior Court (2011) 193 Cal.App.4th 1222, 1237; Felisilda v. FCA US LLC (2020) 53 Cal.App.5th 486, 495-496 (Felisilda); Goldman v. KPMG, LLP (2009) 173 Cal.App.4th 209, 217-218; Crowley Maritime Corp. v. Boston Old Colony Ins. Co. (2008) 158 Cal.App.4th 1061, 1070 [Under equitable estoppel, a party cannot avoid participation in arbitration, where the party received “a direct benefit under the contract containing an arbitration clause…”]; Boucher v. Alliance Title Co, Inc. (2005) 127 Cal.App.4th 262, 271).)

 

Plaintiff in opposition seeks to distinguish the number of cases enforcing an arbitration clause by a third party based on the lack of any established third party beneficiary and/or lack of applicability of estoppel doctrine. Prior to recent cases within the Second Appellate District, auto manufacturers moved to compel on grounds of estoppel and/or third party beneficiary status. (Ngo v. BMW of North America, LLC (9th Cir. 2022) 23 F.4th 942 (“Ngo.”) “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.) The Ngo case involved BMW of North America seeking to compel arbitration over a dispute regarding the financing agreement, and found BMW of North America lacked any basis to compel arbitration as a third party beneficiary, due to the failure to establish any third party beneficiary status. (Ngo, supra, at p. 948.)

 

Unlike Ngo, the subject action involves an equitable estoppel basis to compel via a claim against the warranty(ies) provided by the manufacture of the vehicle itself—moving defendant Mercedes-Benz. The Ngo court further differentiated claims between a credit financing agreement and warranty claims. (Id. at pp. 948-950.) The court therefore distinguishes Ngo in that the complaint arises from the express and implied warranties offered and required by the manufacturer, rather than terms regarding the financed purchase of the vehicle. Plaintiff names no other defendants as responsible for adherence to the warranty (e.g. Keyes European).

 

Furthermore, a leading case decided in the Second Appellate District distinguishes the contractual basis of warranty claims. (Ford Motor Warranty Cases (Ochoa) (2023) 89 Cal.App.5th 1324.) The Ford Motor Warranty Cases specifically confronted the exact situation regarding a third party non-signatory manufacturer seeking to compel arbitration(s) via (a) sales contract(s) of the various purchasing parties for 2015-2016 manufacturing dated vehicles. The court categorically distinguished Felisilda whereby non-signatory manufacturers could compel arbitration on grounds of equitable estoppel. The holding, at least in part, relies on a finding that the warranty obligations, and therefore claims against the manufacturer arise independently from the sales contract. (Id. at p. 1324, 133-1334.)

 

The court also found that Ford Motor Company was precluded from making an argument as a third party beneficiary, due to the failure to establish any showing within the express terms of the contract. (Id. at pp. 1334-1335) Another recent case in the Second Appellate District on the subject affirms the holding of the Ford Warranty case on both equitable estoppel and third party beneficiary theories. (Montemayor v. Ford Motor Co. (2023) 92 Cal.App.5th 958, 971-974.) The Third Appellate District recently granted a writ of mandate reversing an order compelling arbitration citing the Second District opinions in support. (Kielar v. Superior Court (2023) 94 Cal.App.5th 614, 619-621.)

 

To the extent Mercedes-Benz may depend on a finding of privity of contract among the parties and therefore a basis of standing for enforcement of the warranties, the court also finds no basis of enforcement. As addressed in the plain language of the Song-Beverly Act statute, along with other California law, purchasers gain vested warranties with the purchase of new and certain used automobiles. The Ford Motor Warranty Cases specifically found the arbitration clause within the finance contracts constitutes a separate and independent consideration from said legally vested warranties imposed outside the purchase contract context. (Ford Motor Warranty Cases, supra, 89 Cal.App.5th at pp. 1334-1335.) The Ford Motor Warranty Cases court specifically decoupled inherently owed warranties from contractual principles governing arbitration. In separating the governing spheres, the court specifically found warranties shall not be governed by sales contracts. (Id. at pp. 1335-1336.) The court also specifically held that said contracts lack evidence in support of any independent argument for a third party beneficiary relationship. (Id. at pp. 1336-1337.)

 

The California Supreme Court granted review of the Ford Motor Warranty Cases, Montemayor, and Kielar. “Grant of review by the Supreme Court of a decision by the Court of Appeal does not affect the appellate court's certification of the opinion for full or partial publication under rule 8.1105(b) or rule 8.1110, but any such Court of Appeal opinion, whether officially published in hard copy or electronically, must be accompanied by a prominent notation advising that review by the Supreme Court has been granted. [¶] (2) The Supreme Court may order that an opinion certified for publication is not to be published or that an opinion not certified is to be published. The Supreme Court may also order depublication of part of an opinion at any time after granting review.” (Cal. Rules of Court, rule 8.1105(e)(1)(B), (e)(2).) “Pending review and filing of the Supreme Court's opinion, unless otherwise ordered by the Supreme Court under (3), a published opinion of a Court of Appeal in the matter has no binding or precedential effect, and may be cited for potentially persuasive value only. Any citation to the Court of Appeal opinion must also note the grant of review and any subsequent action by the Supreme Court.” (Cal. Rules of Court, 8.1115(e)(1).)

 

Notwithstanding the California Supreme Court review, the court still considers the cases persuasive impacts. “As a practical matter, a superior court ordinarily will follow an appellate opinion emanating from its own district even though it is not bound to do so. Superior courts in other appellate districts may pick and choose between conflicting lines of authority.” (McCallum v. McCallum (1987) 190 Cal.App.3d 308, 315 (footnote 4).)

 

The court finds the reasoning of Ford Motor Warranty Cases, regarding the legal separation of warranty obligations from sales contract arbitration contract principles sufficiently dissociates any findings of an inextricably intertwined contractual relationship on grounds of estoppel between Plaintiff and Mercedes-Benz. The motion otherwise lacks sufficient argument or evidence establishing a third party beneficiary relationship, or authority of the Keyes European representative from executing the agreement on behalf of Mercedes-Benz. The court finds no distinction in the instant lease agreement from the agreement(s) considered in the Ford case. Thus, for both court policy reasons, and factual agreement with the Ford Motor Warranty Cases, Montemayor, and Kielar, the court continues to adhere to the subject authority pending California Supreme Court review.

 

The motion is therefore denied.

 

Trial scheduled for February 3, 2025.

Defendant to provide notice.