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Supreme Court of California - 99 Cal. Rptr.2d 745, 6 P.3d 669, 24 Cal. 4th 83
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Case Summary
In Armendariz v. Foundation Health Psychcare Services, Inc. (2000), the California Supreme Court reviewed a case about the fairness and legality of a mandatory arbitration clause found in an employment contract. The case reached the state supreme court after two lower courts denied the defendant's request to enforce the arbitration agreement. Armendariz and fellow employees sued their employer, Foundation Health Psychcare Services, for wrongful termination, discrimination, harassment, and retaliation under California law. The contract they had signed included an arbitration clause, but the courts found it unfair and unenforceable.
The California Supreme Court agreed, stating that to be enforceable, the arbitration agreement must meet specific minimum standards to protect employees' legal rights. These include: a neutral arbitrator, allowing fair discovery, a written decision suitable for review, and reasonable costs and fees. Additionally, the court ruled the agreement must be balanced and not impose unfair conditions on employees while relieving the employer of similar responsibilities.
This case is significant as it demonstrates that arbitration agreements in employment contracts must respect public policy and adhere to relevant laws. Courts can use the doctrine of unconscionability to nullify excessive or oppressive clauses in such agreements. This decision helps balance the interests of both employers and employees when settling disputes through arbitration rather than going to court.
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The Supreme Court ruled that mandatory employment arbitration agreements covering state and federal antidiscrimination claims are allowed, but the specific arbitration agreement in question was unconscionable due to a damages limitation that is contrary to public policy and because it is unconscionably unilateral. The court emphasized the importance of closely examining arbitration agreements that cover unwaivable statutory rights to ensure they do not waive or impose burdens on such rights. The damages limitation in the arbitration agreement was found to apply to all claims, including statutory claims, making it illegal as it went against public policies. The Court of Appeal's decision upholding the employer's petition to compel arbitration is reversed, and the case is remanded to the Court of Appeal to affirm the trial court's judgment.
Justice Brown agrees with the majority's reasoning on mandatory arbitration and statutory claims, but disagrees with their approach to apportioning arbitral costs. The majority's approach, which places the burden of all costs unique to arbitration on the employer, is too simplistic and not necessarily correct. Justice Brown believes that the issue of apportionment should be left to the arbitrator, and any issues with the arbitrator's decision should be addressed during judicial review. The majority's approach fails to consider the individual circumstances of each case, and courts cannot conclude that the payment of fees will constitute a barrier to the vindication of statutory rights without knowing the exact amount the employee must pay.
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