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To Sever or Not to Sever, That is the Question For Courts Reviewing Employment Arbitration Agreements for Enforceability

Less than a year ago, the California Supreme Court in Ramirez v. Charter Communications, Inc. opined, in the context of employment arbitration agreements, that there is no bright line rule that requires a court to refuse...more

Another Day, Another Dispute Between Appellate Courts Over Employment Arbitrations

The case of Parra Rodriguez v. Packers Sanitation Services LTD., LLC typifies the reason employers and employment counsel must stay on top of arbitration case developments....more

An Attorney’s Inadvertence, Mistake, or Excusable Neglect Is Not Sufficient to Overcome The Bright-Line Rule for Arbitration Fee...

Since its enactment in 2019, Code of Civil Procedure 1281.98, which governs arbitration fee payments, has been inviolate: arbitrators do not have the unilateral power to extend the fee payment deadline; “checks in the mail”...more

Sexual Harassment Claims Preclude Arbitration Even if the Federal Arbitration Act is Not Explicitly Invoked in an Arbitration...

The Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (the “Act”), a federal law, is unique for its role in overriding the policy in favor of the enforcement of arbitration agreements.  The Act was...more

Arbitration Fee Payment Statute Does Not Apply To Post-Dispute Arbitration Agreements

There is no greater threat to an employment arbitration than Code of Civil Procedure section 1281.98, which mandates that the party who drafted the arbitration agreement pay the fees and costs of the arbitration within 30...more

Every PAGA Action Has An Individual Component Which May Be Subject To Arbitration

Prior to the United States Supreme Court’s decision in Viking River Cruises Inc. v. Moriana, California courts did not consider the components of a Private Attorneys General Act (“PAGA”) claim. ...more

Equitable Estoppel Can Be Invoked By a Non-Signatory Joint Employer to Compel Arbitration

Tell me if you have heard this one before: ten companies are sued by a former employee as “joint employers”, even though the employee technically worked for, and signed a binding arbitration agreement with, only one of them....more

Single Sexual Harassment Claim Eliminates Arbitration of All Employment-Related Claims in the Same Case

In 2022, Congress enacted the “Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act” (the “Act”) which provides that, at the election of the person alleging conduct constituting a sexual harassment dispute or...more

“Prejudice” No Longer an Element to Determine Waiver of Right to Compel Arbitration

In 2003, the California Supreme Court adopted a stringent test to determine whether an employer had waived its right to compel arbitration of an employee’s claims.  The most critical, and often determinative, factor was...more

Severing Unconscionable Terms in Employment Arbitration Agreements

In August 2000, the California Supreme Court handed down a landmark ruling that changed the face of employment arbitration agreements going forward. That case, known as Armendariz v. Foundation Health Psychcare Services,...more

Overbroad Employment Arbitration Agreements Will Not Be Enforced in California

Arbitration agreements, at their core, are contracts. As with any contract, there must be “mutuality” or, more colloquially, a “meeting of the minds” on what the contract is intended to encompass. For this reason, employment...more

The Battle for Supremacy: Federal Arbitration Act v. California Arbitration Act

Since its enactment, California courts have universally established the California Code of Civil Procedure section 1281.97 et seq., which governs the timely payment of fees in arbitration, allows no room for error....more

Another Blow to E-Signed Arbitration Agreements in California

Over the last decade, the use of e-signatures has become the norm for human resources departments when onboarding new employees. The advent of resources like DocuSign, Taleo, BabooHR, and others have made this process simple,...more

Previous Arbitration Agreements Are Potentially Unenforceable Against Re-Hired Employees

Despite its best efforts, the California Legislature has been unable to substantially curtail the popularity of employment arbitrations in California.  The hostility to employment arbitration remains evident, however, among...more

When Does a “Dispute” Arise Under the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act?

In 2022, Congress enacted the “Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act” (the “Act”) which provides that, at the election of the person alleging conduct constituting a sexual harassment dispute or...more

California Court of Appeals Reinforces Strict Limits on Arbitration Fee Payment Deadline

The California Court of Appeals recently revisited the issue of the draconian deadline for paying arbitration fees established by California Code of Civil Procedure section 1281.97. In Suarez v. Superior Court of San Diego...more

Appealing A Petition to Compel Arbitration Ruling No Longer Automatically Stays Superior Court Proceedings

Over the past few years, this blog has followed the California Legislature’s concerted efforts to vitiate employment arbitrations in the state. Senate Bill 365 is the next in line....more

California Supreme Court Rules that PAGA Claims May Be Pursued in Court Despite Arbitration Agreement

Following the United States Supreme Court’s landmark ruling in Moriana v. Viking River Cruises, California courts were tasked with the open question of whether an “aggrieved” employee whose individual Private Attorneys...more

California Court of Appeals Holds that Joint Employers Must Sign Arbitration Agreement

In law school, aspiring attorneys are taught fundamental concepts related to contracts, including “agency”, “third party beneficiary”, and “equitable estoppel”, terms which relate to determining who should be subject to the...more

Arbitration Agreements Can Be A Condition of Employment Once Again

The saga of challenges to mandatory employment arbitration agreements is almost over. After three years of challenges, the United States Chamber of Commerce successfully appealed the enactment and enforcement of California’s...more

When Substantial Compliance Is Not Enough: A Cautionary Ruling For Employment Arbitration Actions

Since its enactment in 2020, employers have been forced to be mindful of the burdensome imposition of Code of Civil Procedure section 1281.97 et seq., which requires an employer to pay the full amount of arbitration fees...more

Update: Challenge to California’s Arbitration Agreement Law Marches On

​​​​​​​Employers throughout California have been keenly awaiting the final decision from the 9th Circuit Court of Appeals regarding the United States Chamber of Commerce’s challenge to California Labor Code section 432.6,...more

United States Supreme Court Overrules Ban on PAGA Arbitrations

Private Attorneys General Act (“PAGA”) actions are the proverbial boogeyman to California employers. On June 15, 2022, the United States Supreme Court reined in some of this statute’s bite by holding that “aggrieved...more

Supreme Court Hears Oral Argument on Arbitrability of California's Private Attorneys’ General Act Under Federal Arbitration Act

Since the California Supreme Court’s ruling in Iskanian v. CLS Transportation Los Angeles, LLC in 2014, it has been widely understood that Private Attorneys’ General Act (“PAGA”) actions cannot be subject to employment...more

Mandatory Arbitration Agreements in California: Down, But Possibly Not Out

Businesses and attorneys alike have kept a close eye on the developments surrounding the challenge to California Assembly Bill 51 (now codified as Labor Code section 432.6). Most recently, in a 2-1 decision, the 9th Circuit...more

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