Luckert v. Tesla Energy Operations, Inc.
- Vince Chhabria
- 3:21-cv-03027
- U.S. District Court · Northern District of California
- 2
In Luckert v. Tesla, Judge Chhabria granted Tesla’s motion to compel arbitration and dismissed the case without prejudice because the agreement assigned arbitrability disputes to the arbitrator.
The Luckerts and Tesla Energy Operations, Inc.; the case was sent to arbitration and dismissed without prejudice.
What happened
In Luckert v. Tesla Energy Operations, Inc., the Luckerts and Tesla had a Power Purchase Agreement containing an arbitration provision. That provision incorporated the JAMS Streamlined Arbitration Rules.
Tesla asked the court to compel arbitration. The incorporated rules state that the arbitrator—not the court—must decide disputes about whether the arbitration agreement exists, is valid, or covers a particular dispute.
Judge Chhabria granted Tesla’s motion to compel arbitration and dismissed the case without prejudice. The order did not decide the underlying dispute between the parties.
The detailed version
- Luckert v. Tesla Energy Operations, Inc. · No. 3:21-cv-03027
- Vince Chhabria
- Aug. 5, 2021
Background
The Luckerts and Tesla entered into a Power Purchase Agreement containing an arbitration provision. The agreement incorporated the JAMS Streamlined Arbitration Rules.
Reasoning
The incorporated rules provide that disputes about jurisdiction and arbitrability—including disputes concerning the formation, existence, validity, interpretation, or scope of the agreement—must be submitted to and decided by the arbitrator. “Arbitrability” means whether a dispute must be handled in arbitration. The court relied on Ninth Circuit and Northern District of California decisions holding that this type of language clearly and unmistakably delegates arbitrability questions to the arbitrator.
Disposition
Judge Chhabria granted Tesla’s motion to compel arbitration. The court also dismissed the case without prejudice. The opinion did not decide the merits of the parties’ underlying dispute.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.