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Questions and Answers
What is the basis of the court's decision regarding public injunctive relief in arbitration?
What is the basis of the court's decision regarding public injunctive relief in arbitration?
What cases did the court cite to support its decision regarding public injunctive relief in arbitration?
What cases did the court cite to support its decision regarding public injunctive relief in arbitration?
Did Ring's severability clause argument succeed in court?
Did Ring's severability clause argument succeed in court?
What did the court rule regarding the trial court's jurisdiction to consider Ring's motion for reconsideration?
What did the court rule regarding the trial court's jurisdiction to consider Ring's motion for reconsideration?
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What is the basis of the appellate court's review of judgments or orders?
What is the basis of the appellate court's review of judgments or orders?
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What was Ring's argument regarding the version of its terms of service that governed the arbitration provision?
What was Ring's argument regarding the version of its terms of service that governed the arbitration provision?
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Did the trial court accept Ring's argument that Exhibit K controlled the arbitration provision?
Did the trial court accept Ring's argument that Exhibit K controlled the arbitration provision?
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What did the court emphasize about its decision regarding public injunctive relief in arbitration?
What did the court emphasize about its decision regarding public injunctive relief in arbitration?
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What was the outcome of the appeal of the motion to compel arbitration?
What was the outcome of the appeal of the motion to compel arbitration?
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According to the court's ruling, can arbitration agreements waive public injunctive relief?
According to the court's ruling, can arbitration agreements waive public injunctive relief?
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What cases did the court cite to support its ruling?
What cases did the court cite to support its ruling?
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Did Ring argue that its arbitration provision allows for public injunctive relief?
Did Ring argue that its arbitration provision allows for public injunctive relief?
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What is the basis of the court's decision on the enforceability of the arbitration provision?
What is the basis of the court's decision on the enforceability of the arbitration provision?
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What is the court's ruling on Ring's argument regarding the severability clause in the arbitration provision?
What is the court's ruling on Ring's argument regarding the severability clause in the arbitration provision?
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What is the court's ruling on Ring's request to supplement the record?
What is the court's ruling on Ring's request to supplement the record?
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What is the basis for the trial court's lack of jurisdiction to consider Ring's motion for reconsideration?
What is the basis for the trial court's lack of jurisdiction to consider Ring's motion for reconsideration?
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Does the court's decision mean that arbitration agreements are unenforceable?
Does the court's decision mean that arbitration agreements are unenforceable?
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What is the outcome of the court's ruling on the appeal of the motion to compel arbitration?
What is the outcome of the court's ruling on the appeal of the motion to compel arbitration?
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Study Notes
California Court Rules Arbitration Agreements Cannot Waive Public Injunctive Relief
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Ring argues that its arbitration provision allows for public injunctive relief, but the court disagrees and rules that the provision does not permit such relief.
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The court cites previous cases, including DiCarlo, McArdle, and MacClelland, that interpret similar arbitration provisions to preclude public injunctive relief in arbitration.
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Ring also cites Maynez and Maybaum, two cases that allow for public injunctive relief in arbitration, but the court finds that they do not persuade it to depart from the previous rulings.
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The court notes that its decision is based on a matter of contract interpretation rather than a per se rule that bilateral arbitration agreements requiring arbitration of public injunctive relief are unenforceable.
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The court rules that the Federal Arbitration Act (FAA) does not preempt its decision because it does not prohibit the arbitration of a particular type of claim.
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The court explains that its decision is based on the arbitration provision's failure to allow for public injunctive relief in arbitration, not on a waiver of a claimant's statutory right to seek such relief in any forum.
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Ring argues that the arbitration provision's severability clause means that the parts of plaintiffs' claims involving public injunctive relief should be severed from arbitration, but the court disagrees and rules that the entire claims cannot be arbitrated.
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Ring contends that the trial court abused its discretion in denying its request to supplement the record, but the court finds that there was no abuse of discretion.
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Ring also argues that the trial court was incorrect in determining that it lacked jurisdiction to consider Ring's motion for reconsideration after Ring filed its notice of appeal, but the court rules that section 916(a) applies to appeals from denials of motions to compel arbitration.
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The court notes that the parties did not dispute the validity of the arbitration agreement itself, only its interpretation regarding public injunctive relief.
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The court emphasizes that its decision does not mean that arbitration agreements are unenforceable or that public injunctive relief cannot be sought in arbitration.
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The court concludes that the arbitration provision at issue does not permit public injunctive relief in arbitration and that plaintiffs' claims cannot be arbitrated.Appeal of Arbitration Denied Due to Lack of Jurisdiction
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An appeal from the denial of a motion to compel arbitration automatically stays all further trial court proceedings on the merits.
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The stay under section 916(a) applies to any “trial court proceeding [that] directly or indirectly seeks to ‘enforce, vacate or modify [the] appealed judgment or order.’ ”
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The trial court correctly found it lacked jurisdiction to decide Ring’s motion for reconsideration because the motion sought to vacate and modify the order being appealed.
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The trial court lacked subject matter jurisdiction to continue to entertain the reconsideration motion, as of the time that the appellant filed its appeal.
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Appellate courts do not make factual findings; we review ‘ “the correctness of a judgment [or order] as of the time of its rendition.” ’
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To the extent Ring’s argument is that the trial court erred—and was required as a matter of law to find that the December 2020 version of the arbitration provision applies to plaintiffs’ claims—we reject this argument.
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In its moving papers, Ring did not identify which of 10 versions of its terms of service it believed governed.
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When it quoted the arbitration provision, Ring cited Exhibits C and G and never specifically cited Exhibit K.
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Ring first asserted Exhibit K should control in its reply papers.
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A trial court has discretion whether “to accept arguments or evidence made for the first time in reply.”
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Thus, it was within the trial court’s discretion to reject Ring’s new argument that Exhibit K controlled.
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The order denying the motion to compel arbitration is affirmed.
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Description
Test your legal knowledge with these two quizzes on recent California court rulings. The first quiz focuses on the ruling that arbitration agreements cannot waive public injunctive relief. Learn about the court's interpretation of similar arbitration provisions and their decision based on contract interpretation. The second quiz covers the denial of an appeal for arbitration due to lack of jurisdiction. Test your understanding of the stay under section 916(a) and the trial court's jurisdiction to entertain a reconsideration motion. Sharpen your legal skills with these quizzes
