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AB 51—Preempted, or Not Preempted? That Remains the Question

Seyfarth Synopsis: A divided Ninth Circuit panel has held that employer attempts to impose mandatory arbitration agreements on applicants or employees can be criminally and civilly penalized in California, and thus struck...more

California Supreme Court Declines To Rein In PAGA Plaintiff’s Standing

Seyfarth Synopsis: The California Supreme Court has held that, under the Private Attorneys General Act (“PAGA”), an employee does not lose the ability to pursue representative claims as an “aggrieved employee” by virtue of...more

Zombie Apocalypse? Another (Unconstitutional?) California Assault on Arbitration

Seyfarth Synopsis. On Thursday, September 5, 2019, the Legislature passed AB 51. This bill would ban mandatory arbitration agreements with respect to claims under the Labor Code and the Fair Employment and Housing Act while...more

California Invalidates Wage Arbitration Agreement, Inviting U.S. Supreme Court Review

Seyfarth Synopsis: The California Supreme Court invalidated an employment arbitration agreement on August 29, 2019. At issue in OTO, LLC v. Kho was an agreement to arbitrate employment claims, including wage claims. Under the...more

When Is a Civil Penalty Not a Civil Penalty?

Seyfarth Synopsis: Plaintiffs cannot circumvent arbitration agreements by characterizing claims for statutory damages as claims for civil penalties. The purported PAGA exemption from arbitration agreements applies only to...more

California Supreme Court Invalidates Contractual Waivers Of Public Injunctive Relief

Seyfarth Synopsis: No California contractual provision, including one in an arbitration agreement, can waive the statutory right to seek injunctive relief to protect the general public. McGill v. Citibank, N.A. (April 6,...more

Absent Express Contract, Arbitrator, Not Court, Rules On Class Arbitrability

Seyfarth Synopsis: The California Supreme Court, in Sandquist v. Lebo Automotive, deviated from rulings of most federal circuit courts to hold that the question of “who decides” whether class arbitration is available—courts...more

Ninth Circuit Steals a PAGe from California Courts’ Playbook

Since the California Supreme Court’s 2014 ruling in Iskanian v. CLS Transportation that claims under the Private Attorneys General Act (“PAGA”) are not subject to arbitration, California federal district courts have rejected...more

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