Quanta Computer Inc. v. Japan Commc’ns Inc., No. B280042 (D2d5 Mar. 16, 2018)
TaiwanCo contracted to make some phones in Taiwan and sell them to JapanCo in Japan. Presumably to pick a neutral forum, the contract chose California law and laid exclusive forum in California, despite the fact that there’s basically no connection here.
Friday, April 27, 2018
Thursday, April 26, 2018
“Applicable State Law” Does Not Include Preempted State Law
Sahei v. White Memorial Med. Cntr., No. B283217 (D2d8 Mar. 14, 2018)
Under California law, special protections are required before party can agree to arbitrate claims brought under the Ralph and Bane Civil Rights Acts. See Civil Code § 51.7, 52.1. These protections, however, are preempted by the FAA, which doesn’t permit states to enact special rules that discriminate against or are hostile to arbitration. On the other hand, preemption won’t apply if the agreement isn’t governed by the FAA or if parties nonetheless agree that their agreement to arbitrate will be governed exclusively by preempted California law.
In this case, the parties’ agreement specifically carved out from the scope of arbitration several categories of generally non-arbitrable claims, as well as “any claim that is non-arbitrable under applicable state or federal law.” So the question comes down to contract interpretation: Does “applicable state law” mean the Ralph and Bane Acts as written, or as applied, i.e., baking in the fact that their anti-arbitration provisions are preempted. Following the U.S. Supreme Court’s 2015 decision in DIRECTV v. Imbrugia, the Court takes the as-applied approach. “Applicable state law” incorporates the idea that some state laws are preempted, so the FAA trumps the Ralph and Bane Acts on the arbitrability question.
Reversed.
Under California law, special protections are required before party can agree to arbitrate claims brought under the Ralph and Bane Civil Rights Acts. See Civil Code § 51.7, 52.1. These protections, however, are preempted by the FAA, which doesn’t permit states to enact special rules that discriminate against or are hostile to arbitration. On the other hand, preemption won’t apply if the agreement isn’t governed by the FAA or if parties nonetheless agree that their agreement to arbitrate will be governed exclusively by preempted California law.
In this case, the parties’ agreement specifically carved out from the scope of arbitration several categories of generally non-arbitrable claims, as well as “any claim that is non-arbitrable under applicable state or federal law.” So the question comes down to contract interpretation: Does “applicable state law” mean the Ralph and Bane Acts as written, or as applied, i.e., baking in the fact that their anti-arbitration provisions are preempted. Following the U.S. Supreme Court’s 2015 decision in DIRECTV v. Imbrugia, the Court takes the as-applied approach. “Applicable state law” incorporates the idea that some state laws are preempted, so the FAA trumps the Ralph and Bane Acts on the arbitrability question.
Reversed.
Wednesday, April 25, 2018
Angry, But Not Frivolous
Ponce v. Wells Fargo, No. C080680 (D3 Mar. 13, 2018)
Code of Civil Procedure §128.7(b)(1) authorizes sanctions against a party or attorney who signs a document “presented primarily for an improper purpose[.]” In this case—some kind of confusing mortgage mod/foreclosure dispute on its fourth iteration—the court found that Plaintiffs brought their complaint for an improper purpose and entered terminating sanctions under § 128.7(b)(1).
Plaintiffs don’t seem to dispute that they might have been subjectively malicious. But they say they nonetheless can’t be sanctioned under § 128.7, because their lawsuit was based on an at least colorable theory. Relying mostly on federal authority interpreting Rule 11, the Court of Appeal agrees. The standard for “improper purpose” sanctions requires the signed paper to be without objective merit. If the paper—whether a motion, complaint, or otherwise—isn’t frivolous, it has not been brought for an “improper purpose,” as a matter of law.
Reversed.
Code of Civil Procedure §128.7(b)(1) authorizes sanctions against a party or attorney who signs a document “presented primarily for an improper purpose[.]” In this case—some kind of confusing mortgage mod/foreclosure dispute on its fourth iteration—the court found that Plaintiffs brought their complaint for an improper purpose and entered terminating sanctions under § 128.7(b)(1).
Plaintiffs don’t seem to dispute that they might have been subjectively malicious. But they say they nonetheless can’t be sanctioned under § 128.7, because their lawsuit was based on an at least colorable theory. Relying mostly on federal authority interpreting Rule 11, the Court of Appeal agrees. The standard for “improper purpose” sanctions requires the signed paper to be without objective merit. If the paper—whether a motion, complaint, or otherwise—isn’t frivolous, it has not been brought for an “improper purpose,” as a matter of law.
Reversed.
Tuesday, April 24, 2018
Some Arguments Might Have Been Left on the Table...
AO Alfa Bank v. Yakovlev, No. D071872 (D4d1 Apr. 3, 2018)
This is an action by a Russian Bank under the Uniform Foreign Country Money Judgments Recognition Act, Code Civ. Proc. §§ 1713–25. The Bank wants to collect on a $30 million default judgment against a Russian national who since sought political asylum in the US, settled in San Diego, and took work as an Uber driver.
This is an action by a Russian Bank under the Uniform Foreign Country Money Judgments Recognition Act, Code Civ. Proc. §§ 1713–25. The Bank wants to collect on a $30 million default judgment against a Russian national who since sought political asylum in the US, settled in San Diego, and took work as an Uber driver.
Monday, April 23, 2018
Get Too Meta; Face a SLAPP
MMM Holdings v. Reich, No. G053739 (D4d3 Mar. 12, 2018)
Q: What almost always happens when you sue someone for something they did in another litigation?
A: You lose an anti-SLAPP motion.
Q: What almost always happens when you sue someone for something they did in another litigation?
A: You lose an anti-SLAPP motion.
Friday, April 20, 2018
A Trade Association Is Not an Official Proceeding
Kettler v. Gould, No. B282160 (D2d8 Apr. 20, 2018)
Some Heirs are upset with the Trustee who manages their late parents’ trust, to which Heirs are beneficiaries. Heirs complained about Trustee’s conduct, quite vociferously. They accused him of embezzlement, elder abuse, perjury, and a bunch of other bad stuff to, among others, FINRA, the California Department of Insurance, the Certified Financial Planners Board of Standards, Trustee’s employer, and an insurance company.
Some Heirs are upset with the Trustee who manages their late parents’ trust, to which Heirs are beneficiaries. Heirs complained about Trustee’s conduct, quite vociferously. They accused him of embezzlement, elder abuse, perjury, and a bunch of other bad stuff to, among others, FINRA, the California Department of Insurance, the Certified Financial Planners Board of Standards, Trustee’s employer, and an insurance company.
Wednesday, April 18, 2018
Ninety Days of Tolling
Selvidge v. Tang, No. C083427 (D3 Mar. 5, 2018)
Under Code of Civil Procedure § 340.5, the statute of limitations for med-mal is one year or three years after discovery of the injury. The patient in this case died, so it’s a one year clock. Plaintiff—patient’s next of kin—sued almost three months after the year and run, so she’s too late under § 340.5.
Under Code of Civil Procedure § 340.5, the statute of limitations for med-mal is one year or three years after discovery of the injury. The patient in this case died, so it’s a one year clock. Plaintiff—patient’s next of kin—sued almost three months after the year and run, so she’s too late under § 340.5.
Tuesday, April 17, 2018
Eject!!!
Shapira v. Lifetech Res., No. B283445 (D2d4 Apr. 17, 2018)
At trial, prior to making his closing argument, Plaintiff, sensing he was going down, tried to dismiss his case with prejudice under Code of Civil Procedure § 581(e). The trial court denied the motion and, after ruling for Defendant on the merits, awarded Defendant a substantial amount of attorneys' fees under Civil Code § 1717.
But that was error.
Section 581(e) expressly permits a plaintiff to voluntarily dismiss a case, with prejudice, after the commencement of trial. If the dismissal is requested prior to the case being submitted for decision—which was not the case here because closings were not complete—leave of court is not required. So the trial court didn't have authority to deny the dismissal. And since Civil Code § 1717(b)(2) says there is no prevailing party when a case is terminated by voluntary dismissal, it was therefore also error to award fees to defendant.
It might not seem fair to let Plaintiff weasel out of a fee award when he bailed while on the cusp of losing, but that’s what the law says.
Reversed.
At trial, prior to making his closing argument, Plaintiff, sensing he was going down, tried to dismiss his case with prejudice under Code of Civil Procedure § 581(e). The trial court denied the motion and, after ruling for Defendant on the merits, awarded Defendant a substantial amount of attorneys' fees under Civil Code § 1717.
But that was error.
Section 581(e) expressly permits a plaintiff to voluntarily dismiss a case, with prejudice, after the commencement of trial. If the dismissal is requested prior to the case being submitted for decision—which was not the case here because closings were not complete—leave of court is not required. So the trial court didn't have authority to deny the dismissal. And since Civil Code § 1717(b)(2) says there is no prevailing party when a case is terminated by voluntary dismissal, it was therefore also error to award fees to defendant.
It might not seem fair to let Plaintiff weasel out of a fee award when he bailed while on the cusp of losing, but that’s what the law says.
Reversed.
A Lawsuit over a Lawsuit Meets the Bar of § 47(b)
Herterich v. Peltner, No. A147554 (D1d2, as modified Mar. 28, 2018)
Plaintiff, a disinherited Son in a probate dispute, sued Executor and his Attorney for making various statements alleged to be false during the probate case. The trial court ruled against Son on the merits. He appealed. The Court of Appeal, however, noticed that there’s something more fundamentally problematic about this lawsuit—it is a lawsuit over a lawsuit. So it ordered briefing on whether the litigation privilege in Civil Code § 47(b) bars Son’s claim. It does.
Of course, Executor and Attorney didn’t raise that defense in the trial court, so Son claims they waived it. But the Court doesn’t find that to be much of a barrier, because it presents a pure question of law applied to undisputed facts. Appellate courts have the discretion to consider purely legal questions first raised on appeal. The Court elects to do so here.
As the Court explains, § 47(b) can and has been applied to lawsuits based on alleged fraudulent representations made in the course of prior probate proceedings. The fact that the probate code puts specific duties of candor on executors and their representatives does not vitiate the privilege in some later case. None of these statutory duties are fundamentally inconsistent with privileging statements made during the course of litigation from serving as the basis of future liability in tort. To the contrary, if a party is defrauding the court in a probate proceeding, the remedy for that fraud is in the probate case itself—including various procedures that permit for post-judgment relief—not by filing a separate lawsuit.
Affirmed.
Plaintiff, a disinherited Son in a probate dispute, sued Executor and his Attorney for making various statements alleged to be false during the probate case. The trial court ruled against Son on the merits. He appealed. The Court of Appeal, however, noticed that there’s something more fundamentally problematic about this lawsuit—it is a lawsuit over a lawsuit. So it ordered briefing on whether the litigation privilege in Civil Code § 47(b) bars Son’s claim. It does.
Of course, Executor and Attorney didn’t raise that defense in the trial court, so Son claims they waived it. But the Court doesn’t find that to be much of a barrier, because it presents a pure question of law applied to undisputed facts. Appellate courts have the discretion to consider purely legal questions first raised on appeal. The Court elects to do so here.
As the Court explains, § 47(b) can and has been applied to lawsuits based on alleged fraudulent representations made in the course of prior probate proceedings. The fact that the probate code puts specific duties of candor on executors and their representatives does not vitiate the privilege in some later case. None of these statutory duties are fundamentally inconsistent with privileging statements made during the course of litigation from serving as the basis of future liability in tort. To the contrary, if a party is defrauding the court in a probate proceeding, the remedy for that fraud is in the probate case itself—including various procedures that permit for post-judgment relief—not by filing a separate lawsuit.
Affirmed.
Friday, April 13, 2018
Evidence of Inconclusivess Meets SJ Burden
Leyva v. Garcia, No. F073398 (D5 Feb. 28, 2018)
The Court here affirms a grant of summary judgment in favor of defendant, an apartment owner, in a negligence case brought by tenants injured in a fire. The opinion contains a good discussion of the moving party’s burden under California law.
The Court here affirms a grant of summary judgment in favor of defendant, an apartment owner, in a negligence case brought by tenants injured in a fire. The opinion contains a good discussion of the moving party’s burden under California law.
Thursday, April 12, 2018
Hagueness
Inversiones Papaluchi v. Superior Court, No. B285092 (D2d5 Feb. 27, 2018)
For some random reason, cases arising from helicopters crashes in South America seem to loom large in the jurisprudence of personal jurisdiction and service of process. This is another one.
For some random reason, cases arising from helicopters crashes in South America seem to loom large in the jurisprudence of personal jurisdiction and service of process. This is another one.
Wednesday, April 11, 2018
Party-Appointed Appraiser Is Still an Arbitrator
Khorsand v. Liberty Mutual Ins. Co., No. B280273 (D2d4 Feb. 27, 2018)
Evidence Code § 703.5 strictly limits the admissibility of testimony from judges, referees, arbitrators, and mediators. There are exceptions, including when offered to prove contempt, a crime, judicial misconduct, or a grounds for disqualification. The court here accepts that an effort to prove that a ruling in an insurance claim-related appraisal (a form of arbitration) was procured by fraud falls within those exceptions. Although there’s not much analysis as to why.
But the court rejects a broader claim for admissibility on the basis that the appraiser who offered the declaration doesn’t count as an arbitrator. The procedural setup entailed each party appointing an appraiser, and then the two party appointees appointing a third appraiser, who is commonly called the “referee.” The declarant was one of the party appointed appraisers. The Court holds that even though a party-appointed appraiser might not be considered completely neutral, that doesn’t take him outside of the role of an arbitrator, and thus not outside of the exclusion under § 703.5.
Affirmed.
Evidence Code § 703.5 strictly limits the admissibility of testimony from judges, referees, arbitrators, and mediators. There are exceptions, including when offered to prove contempt, a crime, judicial misconduct, or a grounds for disqualification. The court here accepts that an effort to prove that a ruling in an insurance claim-related appraisal (a form of arbitration) was procured by fraud falls within those exceptions. Although there’s not much analysis as to why.
But the court rejects a broader claim for admissibility on the basis that the appraiser who offered the declaration doesn’t count as an arbitrator. The procedural setup entailed each party appointing an appraiser, and then the two party appointees appointing a third appraiser, who is commonly called the “referee.” The declarant was one of the party appointed appraisers. The Court holds that even though a party-appointed appraiser might not be considered completely neutral, that doesn’t take him outside of the role of an arbitrator, and thus not outside of the exclusion under § 703.5.
Affirmed.
Tuesday, April 10, 2018
Vexer Can't Get Out of Vex Decl. by Using Classic Vex Move
Pittman v. Beck Park Apts. Ltd., No. B266654 (D2d7 Feb. 27, 2018)
Plaintiff was declared a vexatious litigant back in 2010. He’s been trying to get out from under that order ever since. His main argument seems to be that the court that declared him to be vexatious didn’t have jurisdiction to do so, because he voluntarily dismissed the case where the vexatious litigant motion was pending before that decision on the motion. I.e, he tried to avoid being declared a vexatious litigant by using a classic move out of the vexatious litigant textbook.
He’s been raising this argument up and down the courts for the better part of a decade, mostly being stymied by rulings on procedural grounds. So the Court here decides that enough is enough and reaches the merits of his beef. The vacation motion was brought under Code of Civil Procedure § 473(d), which permits a court to vacate a void judgment. A § 473(d) motion doesn’t have a time limit, so long as the voidness can be ascertained from the face of the record, which is the case with Plaintiff’s jurisdiction argument. So the Court of Appeal decides to reach the merits of the argument.
But it’s just another chance for Plaintiff to lose. It is true that a voluntary dismissal generally deprives a court of jurisdiction to enter further orders. There are, however, a bunch of exceptions to this rule, most of which exist to vindicate dismissed parties’ statutory rights on collateral issues that don’t go to the merits. Like when a plaintiff tries to avoid an award of attorneys’ fees or sanctions by dismissing the case. The Court here finds that the same rationales merit retaining jurisdiction to decide a pending motion to have someone declared a vexatious litigant when the litigant tries to weasel out of the finding by dismissing the case.
Plaintiff also raises some other challenges, but the Court finds that they are procedurally barred, for various reasons.
Affirmed.
Plaintiff was declared a vexatious litigant back in 2010. He’s been trying to get out from under that order ever since. His main argument seems to be that the court that declared him to be vexatious didn’t have jurisdiction to do so, because he voluntarily dismissed the case where the vexatious litigant motion was pending before that decision on the motion. I.e, he tried to avoid being declared a vexatious litigant by using a classic move out of the vexatious litigant textbook.
He’s been raising this argument up and down the courts for the better part of a decade, mostly being stymied by rulings on procedural grounds. So the Court here decides that enough is enough and reaches the merits of his beef. The vacation motion was brought under Code of Civil Procedure § 473(d), which permits a court to vacate a void judgment. A § 473(d) motion doesn’t have a time limit, so long as the voidness can be ascertained from the face of the record, which is the case with Plaintiff’s jurisdiction argument. So the Court of Appeal decides to reach the merits of the argument.
But it’s just another chance for Plaintiff to lose. It is true that a voluntary dismissal generally deprives a court of jurisdiction to enter further orders. There are, however, a bunch of exceptions to this rule, most of which exist to vindicate dismissed parties’ statutory rights on collateral issues that don’t go to the merits. Like when a plaintiff tries to avoid an award of attorneys’ fees or sanctions by dismissing the case. The Court here finds that the same rationales merit retaining jurisdiction to decide a pending motion to have someone declared a vexatious litigant when the litigant tries to weasel out of the finding by dismissing the case.
Plaintiff also raises some other challenges, but the Court finds that they are procedurally barred, for various reasons.
Affirmed.
Monday, April 9, 2018
Sue the City, Not Its Employees
Area 51 Prods. v. City of Alameda, No. A144654 (D1d4, on rehearing Feb. 20, 2018)
This opinion takes to heart the key lesson of the Supreme Court’s decision in City of Montebello v. Vasquez, 1 Cal. 5th 409 (2016): While the anti-SLAPP statute generally does not apply to lawsuits challenging the official decisions of government entities, it can apply to lawsuits attacking the participation of individual government employees in coming to and announcing those decisions.
The case is about the City of Alameda’s decision to stop licensing city property to an event planning company for its events. The court here affirms the denial of an anti-SLAPP motion as to the City’s alleged breaches of its contacts with the Event Planner. But it reverses the denial as to the employees of the city and a city contractor who helped managed the licenses. The allegations against these folks were based on their communicative activities related to the City’s official proceedings, and thus protected activity under Code of Civil Procedure § 425.16(e)(2). And since there was no reason they would be held liable on the city’s contracts, Event Planner also had shown no probability of prevailing against them.
Affirmed
This opinion takes to heart the key lesson of the Supreme Court’s decision in City of Montebello v. Vasquez, 1 Cal. 5th 409 (2016): While the anti-SLAPP statute generally does not apply to lawsuits challenging the official decisions of government entities, it can apply to lawsuits attacking the participation of individual government employees in coming to and announcing those decisions.
The case is about the City of Alameda’s decision to stop licensing city property to an event planning company for its events. The court here affirms the denial of an anti-SLAPP motion as to the City’s alleged breaches of its contacts with the Event Planner. But it reverses the denial as to the employees of the city and a city contractor who helped managed the licenses. The allegations against these folks were based on their communicative activities related to the City’s official proceedings, and thus protected activity under Code of Civil Procedure § 425.16(e)(2). And since there was no reason they would be held liable on the city’s contracts, Event Planner also had shown no probability of prevailing against them.
Affirmed
Friday, April 6, 2018
Can't Give a Half-Consent to Arbitrate.
Douglas v. Serenivision, Inc., No. B277574 (D2d2 Feb. 8, 2018)
The law’s pretty clear that unless a contract spells it out clearly otherwise, a court, not the arbitrator, determines the gateway issue of arbitrability. The contract in this case didn’t specify that the arbitrator was to make that decision. But that isn’t dispositive here, because the parties consented by their conduct the arbitrator making that decision.
The law’s pretty clear that unless a contract spells it out clearly otherwise, a court, not the arbitrator, determines the gateway issue of arbitrability. The contract in this case didn’t specify that the arbitrator was to make that decision. But that isn’t dispositive here, because the parties consented by their conduct the arbitrator making that decision.
Thursday, April 5, 2018
Nine Years’ Litigation, Nobody Prevails
Marina Pac. Partners Homeowners Assoc. v. S. Cal. Fin. Corp., No. B276719 (D2d8 Feb. 5, 2018)
Civil Code § 1717 permits a prevailing party to a contract with an attorney fee provision to recover its fees. The trial court is authorized to determine the prevailing party, who is generally the party that receives the greater of the relief. But the code authorizes the court to decide that there isn’t any prevailing party and, under those circumstances, to decline to shift fees. The Supreme Court has instructed that in making a prevailing party determination, the court should look at the relief obtained in the context of the parties’ litigation objectives. Hsu v. Abbara, 9 Cal. 4th 863 (1995). If the case is truly a mixed bag—like where both parties seek relief and neither gets everything it wanted—then the trial court can find there’s no prevailing party.
This is a long running real estate dispute, filed in 2009. I don’t really care to get into the substance, but the dispute is over a fee. Plaintiff wanted to be entirely absolved from paying it. Defendant asserted that it should be 10 percent over the life of the contract. The judgement landed on 4 percent. Now, both sides try to say that the 4 percent was their true objective and thus that they prevailed. (Because you litigate for 9 years when you basically agree, right?) But that really wasn’t what the case was about. Under the circumstances the trial court didn’t abuse its discretion that no party prevailed to the extent that a fee award was merited. Same goes with the court’s declining to award costs under Code of Civil Procedure § 1032.
Affirmed.
Civil Code § 1717 permits a prevailing party to a contract with an attorney fee provision to recover its fees. The trial court is authorized to determine the prevailing party, who is generally the party that receives the greater of the relief. But the code authorizes the court to decide that there isn’t any prevailing party and, under those circumstances, to decline to shift fees. The Supreme Court has instructed that in making a prevailing party determination, the court should look at the relief obtained in the context of the parties’ litigation objectives. Hsu v. Abbara, 9 Cal. 4th 863 (1995). If the case is truly a mixed bag—like where both parties seek relief and neither gets everything it wanted—then the trial court can find there’s no prevailing party.
This is a long running real estate dispute, filed in 2009. I don’t really care to get into the substance, but the dispute is over a fee. Plaintiff wanted to be entirely absolved from paying it. Defendant asserted that it should be 10 percent over the life of the contract. The judgement landed on 4 percent. Now, both sides try to say that the 4 percent was their true objective and thus that they prevailed. (Because you litigate for 9 years when you basically agree, right?) But that really wasn’t what the case was about. Under the circumstances the trial court didn’t abuse its discretion that no party prevailed to the extent that a fee award was merited. Same goes with the court’s declining to award costs under Code of Civil Procedure § 1032.
Affirmed.
Wednesday, April 4, 2018
Plaintiffs' Joint § 998 Offer Holds Up
Gonzalez v. Lew, No. B271312 (D2d3 Mar. 1, 2018)
This is a wrongful death case arising out of a house fire where two people were killed. Plaintiffs made a joint, undifferentiated offer of judgment under Code of Civil Procedure § 998 for $1.5 million. Defendants didn’t accept it, and a jury ultimately awarded $2.6 million. So the Court awarded Plaintiff’s their expert fees and interest on the award from the date the offer expired.
This is a wrongful death case arising out of a house fire where two people were killed. Plaintiffs made a joint, undifferentiated offer of judgment under Code of Civil Procedure § 998 for $1.5 million. Defendants didn’t accept it, and a jury ultimately awarded $2.6 million. So the Court awarded Plaintiff’s their expert fees and interest on the award from the date the offer expired.
Monday, April 2, 2018
New Trial Motion Can't Save Unripe Claim from SLAPP Motion
Aron v. WIB Holdings, No. B271271 (D2d2 Mar. 28, 2108)
Plaintiff in this case won an unlawful detainer trial against his Landlord. While that was on appeal, he sued Landlord for damages under a Santa Monica rent control ordinance that offers a private damages remedy against any landlord who brings a UD action in bad faith. Landlord filed an anti-SLAPP motion. The case clearly arose from the UD action, so it arose from protected activity. And since the Santa Monica ordinance specified on it face that a favorable termination of the UD case was a condition to recovery, the trial court granted the motion, because Plaintiff couldn’t show that he was likely to succeed.
Plaintiff in this case won an unlawful detainer trial against his Landlord. While that was on appeal, he sued Landlord for damages under a Santa Monica rent control ordinance that offers a private damages remedy against any landlord who brings a UD action in bad faith. Landlord filed an anti-SLAPP motion. The case clearly arose from the UD action, so it arose from protected activity. And since the Santa Monica ordinance specified on it face that a favorable termination of the UD case was a condition to recovery, the trial court granted the motion, because Plaintiff couldn’t show that he was likely to succeed.
Some Stuff About Arbitration Awards
EHM Prods., Inc. v. Starline Tours of Hollywood, Inc., No. B281594 (Mar. 28, 2018)
This short opinion about arbitration awards seems pretty straightforward. But when you scratch the surface there’s a bunch of interesting stuff going on.
This short opinion about arbitration awards seems pretty straightforward. But when you scratch the surface there’s a bunch of interesting stuff going on.
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