California Litigation Attorney Blog

CEQA (the California Environmental Quality Act) was enacted to provide the fullest possible protection of the environment when governmental entities make decisions that have the potential of adversely affecting the environment. Historically, and in the context of my professional experience, CEQA issues tend to pop up in large commercial and residential projects. Typically, CEQA petitions are not asserted to stop the construction of a single-family residence.

The reason for this is simple. Single-family residences are relatively small constructions and applying CEQA every time someone wants to build or remodel a single home, would gum up the works, so to speak. Single-family residences fit within an exemption for CEQA review set forth in the California Code of Regulations. However, there are exceptions to the exemptions and the Court of Appeal recently held that the City of Berkeley California violated CEQA by approving the construction of a 10,000 foot home without CEQA review by ruling that it was categorically exempt under CEQA.

In Berkeley Hillside Preservation v. City of Berkeley (Mar. 7, 2012) No. A131254, the Court of Appeal for the First District held that the circumstances particular to the construction of the subject home, fit within one of the exceptions to the exemption for single-family residences, namely, that there were “unusual circumstances” which create “a reasonable possibility” that the activity will result in an adverse impact on the environment. In this case, the activity entailed the construction of a very large home on steep slope near a wooded area.

The significance of the Berkeley Hillside Preservation is more practical than legal. CEQA has broad applications based on the wording of the applicable Statutes and Codes. However, developers and municipalities alike sometimes fail to realize the breadth of the Act when they do their planning. Berkeley Hillside Preservation teaches us to mindful of the possibility of a CEQA issue even on projects that are not typically challenged. In this case, it is highly likely that the property owner seeking to build the 10,000 square foot mansion will receive an unanticipated cost increase for the project…the challengers’ attorneys fees.

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Can the selection of a roommate give rise to a legal claim for discrimination? The Ninth Circuit recently weighed in.

In Fair Housing Council of San Fernando Valley v., 666 F.3d 1216 (9th Cir. 2012), a website that matches roommates based on sex, sexual orientation, and family status, was sued for violation of the anti-discrimination provisions under the federal Fair Housing Act (FHA) and the California Fair Employment & Housing Act (FEHA).  The question addressed in the case was whether the provisions of the FHA and the FEHA limit our right to chose with whom we will live, and if so, whether government interference with our choice violates our constitutional right to privacy.

Common sense would seem to dictate that people have a right to chose who they want to live without being considered discriminatory.  However, in the case, a federal District Court first ruled that the website’s questions requiring disclosure of sex, sexual orientation and family status, and its sorting, and matching of users based upon those characteristics, violated the FHA and the FEHA.  The District Court granted summary judgment for the plaintiff and awarded almost $500,000.00 in attorney’s fees.

The Ninth Circuit Court of Appeals reversed the decision of the District Court, noting that the federal FHA prohibits discrimination on the basis of race, color, religion, sex, familial status, or national origin in the sale or rental of a dwelling.  In addition, California’s FEHA contains substantially similar language and further prohibits discrimination based on sexual orientation and gender identity. Despite this language, the Ninth Circuit was skeptical about whether either Congress or the California legislature intended to govern the selection of roommates.  As noted by the Court in its opinion, if individuals could not discriminate in the selection of roommates based upon gender, then a female could be forced to select a male roommate or be subject to a claim of discrimination. The opinion went on to observe: “Telling women they may not lawfully exclude men from the list of acceptable roommates would be controversial today; it would have been scandalous in the 1960s.”

Ultimately, the Court in the case held that applying the nondiscrimination requirement to roommate selection would constitute a serious invasion of privacy and therefore the anti-discrimination provisions of the FHA and the FEHA do not apply to roommate selection.  Accordingly, roommates remain free to choose their roommates in a manner that might be considered discrimination if the entire housing unit was to be sold or rented.

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medical marijuana collective cooperativeThe California Supreme Court granted review of Inland Empire, Pack, G3, and Evergreen- cases that may change the legal landscape in the litigation between municipalities and medical marijuana dispensaries and collectives.

In the April 11, 2012 edition of the Daily Journal, Stephen A. McEwen, a partner in the Orange County office of Burke Williams & Sorensen LLP, co-authored a an article entitled “Medical marijuana: local land use authority versus state and federal law.” (Subscription Required)

For another recent article by Stephen A. McEwen on the same topic, see Medical Marijuana Update- March 2012.

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past due debtSeveral months ago, I posted a blog on the steps you “should” take in order to effectively collect money that a client or customer owes to you or your company.

In today’s blog, I want to provide you with collection steps you should “not” take in an attempt to collect on a debt. Creditors, collection agencies, and even attorneys can be held liable for abusive collection practices under both federal and state law. Here are a few examples of steps you should avoid taking when attempting to collect on a debt:

1. You may not directly communicate with a consumer to collect on a debt if you know the consumer is represented by an attorney.

2. You may not communicate with a consumer at an unusual time or place. Communications between the hours of 9:00 p.m. and 8:00 a.m. are presumed to be unusual and inconvenient.

3. You may not communicate with a consumer at his or her workplace if you know or should know that the employer prohibits such communications.

4. Generally, you may not communicate with third parties regarding the consumer’s debt (with some exceptions, such as the parties’ attorneys or a credit reporting agency).

5. Even leaving voice-mails that are likely to be overheard by third parties could be considered to be a violation of federal debt collection law.

6. If you communicate with a third party to try to find out the debtor’s location, you must identify yourself and state that the purpose is to try to find the location of the consumer, but you may not state that you are attempting to collect on a debt. You also may only identify your employer if expressly requested.

7. You may not threaten or harass a consumer to collect on a debt. Examples of this include:

a. Implied threats of violence, e.g., “We are not playing around here – we can play tough.”

b. Publishing a “dead beat” list anywhere of, e.g., people who wrote you bad checks.

c. Continuously or repeatedly calling a consumer with the intent to harass (e.g., calling a person more than five times a day after being told not to call again).

8. You may not fail to disclose your identity or mislead the consumer about the nature and purpose of your call.

9. You may not make any false or misleading statements to try to strong-arm a consumer into paying the debt (i.e. falsely stating that you will garnish his wages if he does not pay).

These actions may violate the federal Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. § 1692 et seq. and/or California’s Rosenthal Fair Debt Collection Practices Act, California Civil Code § 1788 et seq.

The debt collection attorneys in California at Reid & Hellyer have extensive experience in the debt collection process. Contact us if you can use some assistance with your collections.

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Boilerplate email disclaimers have become so commonplace that many of us don’t even notice their existence. Are these email disclaimers of any effect?  One website touts the necessity of these lengthy paragraphs, while The Economist wrote in 2011 that these automatic email footers are both annoying and “legally useless.” So who is correct? As you might suspect since a lawyer is writing this, the answer is: it depends.

Confidential Communications

Utilizing email disclaimers to reinforce confidential communication is one use that has shown some evidentiary value. One federal district court ruled that an email beginning with the phrase “PRIVILEGED AND CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION” evidenced the client’s “intent to seek legal advice and the client’s belief that he is consulting an attorney, i.e., someone who will keep the communications confidential.” Mattel, Inc. v. MGA Entm’t, Inc., 2010 U.S. Dist. LEXIS 102461, 23 (C.D. Cal. Sept. 22, 2010).

In fact, the downside of not including such a disclaimer may be detrimental. According to one court, the lack of email disclaimer about the confidentiality of a customer list evidenced that the materials were not intended to be confidential. B & F Sys. v. LeBlanc, 2011 U.S. Dist. LEXIS 103957, 77 (M.D. Ga. Sept. 14, 2011).

Authority to Bind a Principal or Employer

A disclaimer of authority of agents or employees to bind their principals or employers appears to have some effect. One court found such to be evidence of an intention not to form a contract where the disclaimer stated that the email “does not in any case constitute a binding offer, acceptance or opinion for [the principal] unless so set forth in a separate document.” McCoy v. Gamesa Tech. Corp., 2012 U.S. Dist. LEXIS 38745, 17-18 (N.D. Ill. Mar. 22, 2012).

Yet another disclaimer that made clear that an insurance agent did not have the authority to bind an insurance company before a policy was issued was found to be effective. Sunny Corral Mgmt., LLC v. Zurich Am. Ins. Co., 2010 U.S. Dist. LEXIS 46679, 7-8 (N.D. Tex. Mar. 31, 2010).

Preventing Parties with Authority from Forming a Contract

A disclaimer may make it clear that contract terms are not set without further action. One federal district court found that an email disclaimer stating that any “price or other contract term contained in this email is subject to approval” prevented the formation of a valid contract by e-mail alone. Dhillon v. Zions First Nat’l Bank, 2012 U.S. App. LEXIS 4605, 2-3, 9 (11th Cir. Ga. Mar. 6, 2012).

However, an email alone was found insufficient to grant a motion to dismiss where the email disclaimer stated “[t]his is a confidential draft and is not for use by any party for any reason.” Blackwater Techs., Inc. v. Synesi Group, 2008 U.S. Dist. LEXIS 2744, 4, 15 (D. Minn. Jan. 14, 2008). Rather, this was found to be a matter best decided on a motion for summary judgment after the facts could be developed in discovery.

Disclaiming Threats of Violence

One family court case spilled over into an email that stated “pay-back is really a b****” and that the recipients “still have a gigantic debt to pay to me, which will be paid no matter what.” Romero v. Romero, 2011 Cal. App. Unpub. LEXIS 8706 (Cal. App. 4th Dist. Nov. 14, 2011). The e-mail concluded with, “Your most determined, unstoppable, and visceral enemy.”

Below that, the email included the following: “DISCLAIMER: Not one word herein should be construed by anyone as meaning violent or threatening intentions, and instead the entire contents is to be taken by the strict literary meaning. There have not been, and will be any elucidated threats of violence or intent, either expressed or implied, within the entirety of this document.”

Unsurprisingly, the recipient of the e-mail sought a protective order. The sender claimed his emails were protected by his First Amendment right of free speech and that the “disclaimer” prevented the emails from being used as the basis for a protective order. The court explained to the sender that his documented threat and harassment of the recipient would not be ignored “by simply putting a disclaimer on it.”

Effective Use of Email Disclaimers

These cases evidence that the effect of a disclaimer will likely depends upon all of the surrounding circumstances, including the disclaimer’s language, the text of the email at issue and the context in which it was sent.

To maximize the chances that such a disclaimer might be found effective, it may be better practice to place it at the beginning, not the end, of an email.  However, if one were to do that for all e-mails sent, one might wonder if one really meant for the disclaimer to apply. It might be better practice to use disclaimers sparingly to certain particular emails only, not to every email sent.

Notably absent from these cases is any finding by a court that boilerplate language at the bottom of every email about matters that only pertain to certain emails is of any conclusive effect. Such language is often found in attorney emails relating to confidentiality, formation of an attorney-client relationship, or other matters that are disclaimed in an abundance of caution. While that doesn’t mean a court could not find some value in boilerplate language, the lack of such a case is telling.

Are disclaimers “legally useless” as The Economist reports? Probably not, but their effectiveness may be more limited than some believe.

This blog post is the exclusive, private, confidential, and privileged property of the blogger. This information contained in it is intended solely for the use of the blogger and the intended recipient(s).

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In light of the recent decision in Toyota Motor Corporation v. Superior Court (July 27, 2011) 197 Cal. App. 4th 1107, corporate employers with employees located outside California will have to decide whether to agree to send any out-of-state employees to California for future Person Most Qualified/Knowledgeable depositions.

Prior to 2011, if a party noticed a Person Most Qualified/Knowledgeable deposition of a corporate party, a corporation was previously thought to be obligated pursuant to California Code of Civil Procedure section 2025.250, subparts (b), (c), and (d) to produce its PMQ/PMK in California within 75 miles of the organization’s principal office, or if the corporation had no principal office, within the California county where the action was pending.

The Toyota Motor decision, however, now casts doubt regarding whether out-of-state employees can be compelled to travel to California for deposition. Toyota Motor held that employees of Toyota residing in Japan could not be compelled to travel to California for deposition pursuant to California Code of Civil Procedure section 2025.260 (which allows a party to move for a court order compelling the deposition of an individual to occur in a place more distant than that permitted by section 2025.250, i.e., for a natural person, within 75 miles of the person’s residence). The Toyota Motor court reasoned that if an out-of-state witness could not be compelled to testify in California at trial due to the limitations of Code of Civil Procedure section 1989 (which provide that a witness is not obliged to attend trial in California “unless the witness is a resident within the state at the time of service”), then the same logic also prevented a party from compelling an out-of-state witness to participate in a deposition in California.

Although the Toyota Motor court spent the entire opinion laying out its rationale for eliminating the ability of parties to compel out-of-state natural person witness to participate in California depositions, footnote 20 of the opinion specifically states that its analysis and conclusions should not be extended to depositions where the party is not a natural person (ie., PMQ/PMK depositions).

A strong argument, therefore, can now be made in either direction where a party does not want to produce PMQ/PMK’s who reside out-of-state. The corporation can argue that the logic of Toyota Motor should clearly be extended to such depositions insofar as there no practical difference in having to produce a specific out-of-state individual whose deposition was noticed, as opposed to an individual identified by the corporation as its PMQ/PMK. In both cases, the party testifying is an individual. On the flip side, the party noticing the deposition can argue that since the Toyota Motor court limited its opinion to exclude PMQ/PMK testimony, that the law at this time requires PMQ/PMKs to appear in California.

At some point this issue will be cleared up by future Appellate/Supreme Court decisions. Until that time, however, corporate employers will have to make a strategic decision regarding whether contesting the location of the deposition is worth the time, expense, etc.

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Scales of JusticeAttorneys regularly counsel their clients regarding the unpredictability of juries.  The “crap shoot” nature of our jury verdict system often drives settlement discussions.  Less is said regarding the unpredictability of judges.  What are sometimes seen as illogical decisions rendered by judges, however, can cause just as much harm to clients as do erroneous decisions rendered by juries. Hence, we are unsurprised when an appellate court reverses the trial court.

For example, recently a superior court judge issued a tentative ruling at a demurrer hearing in which the judge sustained a demurrer without leave to amend related to a claim for negligent misrepresentation because the plaintiff had not alleged “intent to defraud” as part of the claim.  As any first year law student knows, “intent to defraud” is not an element of a claim for negligent misrepresentation.  Obviously, a misrepresentation made with an intent to defraud is no longer a negligent misrepresentation—it is an intentional misrepresentation.

After being advised of a recent California Supreme Court decision which specifically stated that “intent to defraud” was not an element of a claim for negligent misrepresentation, the judge took the matter under submission—but refused to change his tentative decision.  Although the judge’s decision is certainly subject to review and reversal, the moving party would by necessity have to incur significant expense to appeal a decision that never should have been rendered.

Unfortunately, this instance of a sitting judge issuing a seemingly erroneous decision is not an isolated incident.  Most seasoned trial lawyers can recount any number of occasions when judges “go off the reservation” and issue rulings which seem to have no basis in law.  Even where the decisions are reversed on appeal, needless time and expense is often incurred correcting the erroneous rulings.   So, armed with this information, what should an attorney do?

Attorneys must remind their clients of the pitfalls of every aspect of litigation, including the fallibility of both the juries and judges to correctly rule on what superficially seem to be obvious points of fact or law.  Bench trials (trials by judges) are no panacea for removing unpredictability from the litigation equation.  As noted above, you might be assigned a judge who is convinced that intent to defraud is an element in a claim for negligent misrepresentation.  And instead of learning about the judge’s novel theory on California law early in the litigation at the demurrer stage, what if you are not informed about his theory until you are submitting jury instructions?

The bottom line is that all litigation is a crap shoot and judges are often times no better than juries at determining facts or law. All clients need to be aware that their “great case” is at every stage of litigation just one poorly reasoned judge’s decision away from becoming a money-pit.

The only real way to control the uncertainty of litigation is to urge clients and counsel to always consider mediation, even before litigation, when possible.

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Who are the IRS’s favorite superheroes?  The X-Men.  The IRS loves to hear from ex-spouses, ex-business partners and ex-employees about taxpayers who may not have fully met their federal tax obligations.  The IRS even has official “Whistleblower” programs that reward people for dropping a dime on their follow taxpayers.

The IRS Whistleblower Office pays money to people who blow the whistle on persons who fail to pay the tax that they owe. If the IRS uses information provided by the whistleblower, it can award the whistleblower up to thirty percent of the additional tax, penalty and other amounts it collects.  The IRS only pays awards to people who provide specific and credible information to the IRS and the information results in the collection of taxes, penalties and interest from the target taxpayer.

Internal Revenue Code IRC Section 7623(b) provides for two types of awards. If the taxes, penalties, interest and other amounts in dispute exceed two million dollars, and a few other qualifications are met, the IRS will pay fifteen percent to thirty percent of the amount collected. If the case deals with an individual, his or her annual gross income must be more than two hundred thousand dollars.  The IRS has another award program for whistleblowers who do not meet these income thresholds. The awards through this program are less, with a maximum award of fifteen percent up to ten million dollars.

If you decide to submit information and seek an award for doing so, use IRS Form 211. The same form is used for both award programs.

However, anyone thinking about submitting information under the Whistleblower programs will want to consult with a qualified tax attorney for two main reasons.  The first reason is that a qualified tax attorney can make sure that the Whileblower will not be subject to blow back from their whisleblowing activities.  Many “exes” may be jointly liable for the very taxes that they are providing the IRS information about.  Most clear thinking people would not want to engage in the tax equivalent of a murder suicide pact.  A qualified tax attorney would also help in guiding the whistleblower through the procedural steps of the whistleblower program.

Also, do not think that the Whistleblower programs are a way to get rich quickly.  In a 2010 GAO report to Congress on the program, the IRS said whistleblowers are told that completing a claim could take five to seven years and sometimes longer.   Of course most whistleblowers are motivated by “doing the right thing” and not by revenge on someone who wronged them.

On the other hand, the Whistleblower programs are a reminder that you should not play fast and loose with federal tax rules, especially if there are others around who can drop a dime on you later.  Information is the most valuable commodity; don’t give it away to someone who can use it against you later.

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The documents are clear!

I see another major law firm has been sued for legal malpractice by a hedge fund manager and a distressed investment firm who claim that their lawyers didn’t advise them about a particular term in a deal involving tens of millions of dollars, if not more.

Well, the term’s in writing, isn’t it?  And, it’s clear?  And, it’s not unusual in the field? These were sophisticated clients dealing in tens of millions of dollars in the regular course of business and, yet, they are innocent little lambs who didn’t know what they were doing?  Or, they didn’t read the documents?  Or, they didn’t understand them because their “sophistication” was a thin veneer?

Somehow, this case doesn’t seem to have much jury appeal.  Funny how these clients don’t want their lawyers as their partners on the upside, but want to turn them into guarantors or insurers on the downside.

While a CYA e-mail can be off-putting to clients, I tell them “I’m going to send you a confirming e-mail for future reference in case one of us gets hit by a meteor or something” and then give a little chuckle.  Such an e-mail (three, actually) nipped a client’s implicit claim in the bud recently.  “Oh, yeah, now I remember,” the client told me.  Then he stiffed me on part of my bill anyway.

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Scales of JusticeReprimanded teacher objects to disclosure of the reprimand

The appellate court’s opinion in Marken v. Santa Monica-Malibu Unif. Sch. Dist. (Jan. 24, 2012)  No. B231787 is an excellent recap of the California Public Records Act (Gov. Code sec. 6250, et seq.) with respect to disclosure of certain records of public employees.

The short version is, if the public employee is disciplined in any way, it is almost certain that the public’s interest in knowing that (upon request) outweighs the employee’s privacy rights.

In the Marken case, the teacher was found to have engaged in certain conduct in violation of the school district’s sexual harassment (of students) policy.  A written reprimand was issued.  There was no appeal.

Two years later, a request was made for disclosure of that reprimand and other documents.  The teacher sought an injunction preventing disclosure, claiming a violation of his privacy rights.  Both the trial and appellate courts ruled that the injunction should be denied and the disclosure made (with redactions of certain information pertaining to others).

This is the correct decision for any number of reasons. But, the larger question is, when are some people going to get a clue?

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Landlord Tenant LeaseEconomic times have been difficult for many businesses throughout Southern California during the past few years. In some instances it appears that the economy is on the mend; other times it appears the economy is getting worse. If your business is continuing to suffer, is there any way to get out from under what may now appear to be an unfavorable lease?

The short answer is that you are ultimately responsible for paying rent for the remainder of the lease term if you terminate the lease early.  However, there are some options if you find yourself in this situation:

  • Ask your landlord if he has a smaller unit available that he can rent to you instead. Make sure to document your request in writing. This way, if your landlord ever sues you for rent owed on the remainder of your lease, you can show that you attempted to mitigate or reduce his damages.
  • Find a suitable sub-tenant. You may have vacant office space in your unit available if you have been downsizing. Although you will need to obtain approval from your landlord for any subletting, most leases provide that the landlord will not “unreasonably withhold” consent.
  • Find someone to take over your lease. For instance, you might want to try selling your business and having the new owner take over your lease. The landlord may be required (under the express terms of your lease) to consent to a lease assignment. Keep in mind, though, that most sophisticated landlords will require you to remain on the lease as a guarantor even if they accept the lease assignment. This means that you may be responsible if the new tenant fails to pay the rent. Consequently, you will want to make every effort to ensure that any prospective buyer of your business is financially sound.
  • Renegotiate your lease to reduce your monthly rent. Although not legally required to do so, your landlord may be willing to cut you a break on the rent just to keep you as a tenant. It is tough out there for landlords to keep units filled in today’s economy. Some money is better than no money.
  • In some situations, you may be able to terminate your lease if your landlord failed to perform his obligations (e.g., by failing to use your Common Area Maintenance fees to maintain the premises). If you think your landlord may have breached your lease, you should consult with an attorney.

Reid & Hellyer has extensive experience in assisting business clients in a wide range of business and real estate law issues, including landlord/tenant issues.

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Arbitration AgreementEmployers in California are often faced with lawsuits brought by employees for alleged Labor Code violations. The general perception is that plaintiff employees have a greater chance of obtaining a sizeable recovery against an employer in a jury trial.

The concept is that juries are made up of citizens that are more likely than not to be employees themselves. As a result, there is a preference among employers to avoid having their issues with employees resolved by juries. One potential alternative to resolve such claims is to require binding arbitration.

In Wisdom v. AccentCare, Inc. (Jan. 3, 2012) 2012 DJDAR 105, several employees filed a lawsuit against their employer, AccentCare, Inc., alleging that they were not paid for all of their overtime work. In conjunction with their employment, four of the plaintiffs had signed acknowledgment forms when they applied for employment that included a binding arbitration agreement. The plaintiffs did not negotiate these terms and the terms were not explained to them.

In response to plaintiffs’ complaint, AccentCare brought a motion to compel arbitration of the claims, relying upon the arbitration clause in the employment contract. The trial court denied the motion to compel arbitration, finding that the arbitration provision was both procedurally and substantively unconscionable.

The Court of Appeal in Wisdom upheld the ruling of the trial court, finding that an arbitration provision imposed on employees as a condition of employment, and without the opportunity for negotiation, is adhesive. As noted by the court, in the context of an individual seeking employment, there exists unequal bargaining power between the parties. Moreover, there was no evidence of any negotiation regarding the terms of the agreement between the prospective employee and the employer. Also, there was no indication that the existence of the arbitration clause was brought to the attention of the prospective employee. For these reasons, the arbitration clause was found to be procedurally unconscionable.

The court in Wisdom also noted that the arbitration provision at issue was procedurally unconscionable because it did not create mutual obligations as between the parties. In that regard, under the terms of the arbitration provision, only the employee was agreeing to submit claims to arbitration. For these reasons, the arbitration provision was found to be unenforceable by the employer.

The decision in Wisdom is consistent with prior decisions in California holding that, except in rare circumstances, a binding arbitration provision contained within an employment agreement will generally not be upheld by courts.

In order to make the strongest showing for enforceability, an employer needs to:

  1. Direct the prospective employee’s attention to the arbitration clause;
  2. Request that the prospective employee review the arbitration clause and ask as to whether the prospective employee wants to make any modifications to the arbitration clause;
  3. Allow the employee to strike the arbitration clause while still affording the employee the opportunity to obtain employment; and
  4. Include language in the arbitration clause which clearly indicates that it is mutually binding as to both the employee and the employer.

As a practical matter, under circumstances where an employer has a high volume of employees, for the most part, the employees are not in a position to dictate the terms of their employment. As a result, a binding arbitration provision contained in an employment agreement will likely be found to be unenforceable.

The most probable exception is a situation where a prospective employee is a highly sought after skilled employee that, with the assistance of counsel, engaged in detailed negotiations regarding the terms of the employment relationship. In Wisdom, those factors were not present and therefore the court found the arbitration provision to be unenforceable.

If you are in need of a California employment attorney, contact Reid & Hellyer today.

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