Haynes v. Uponor, Inc.

Background

Hoyt Haynes and Felicia M. Haynes filed a class action against Uponor, Inc. and Uponor North America Inc. The defendants manufacture blue and red cross-linked polyethylene tubing, known as PEX. The plaintiffs own a home in Brentwood, California, that was built with PEX in its drinking-water plumbing system. They purchased the home from Seecon Built Homes, Inc. in September 2016.

The purchase agreement said that the seller was not responsible for warranties on manufactured products and that the buyer would look solely to the manufacturer. It also assigned to the buyer any assignable rights under manufacturers’ warranties for appliances and other consumer products included in the property.

The defendants offered a limited PEX warranty to the owner of the applicable real property. The warranty required unresolved claims to be arbitrated before a single arbitrator in the Minneapolis, Minnesota metropolitan area. It also prohibited either side from arbitrating or litigating claims as a class action or joining or consolidating claims with other parties.

The plaintiffs alleged that they discovered a water leak from the PEX in their master bathroom in October 2019. Their operative complaint asserted claims for strict product liability, negligence, violations of California Civil Code section 895, and violations of the Unfair Business Practices Act. The defendants moved to compel arbitration and, alternatively, moved to dismiss or strike.

Court’s analysis

The court applied the Federal Arbitration Act and California contract-formation principles. It explained that the party seeking arbitration must prove the existence of a valid arbitration agreement and that the court must decide whether the parties agreed to arbitrate and whether the agreement covers the dispute.

The court found that assent was not disputed because the plaintiffs signed the purchase agreement. It concluded that Seecon was a party to the PEX warranty and assigned the warranty, including its arbitration and class-action provisions, to the plaintiffs through the purchase agreement. The court rejected the plaintiffs’ argument that the purchase agreement covered only products meeting the Federal Trade Commission’s definition of consumer products under the Magnuson-Moss Warranty Act. It held that the agreement’s separate definition covering products manufactured off-site applied to the PEX pipes.

The court also stated that the plaintiffs had made prior allegations supporting the conclusion that they were subject to the PEX warranty. It determined that all of the plaintiffs’ claims concerned the quality of the PEX pipes and resulting damages, so all claims fell within the warranty’s arbitration provision.

Ruling

The court granted defendants’ motion to compel arbitration and stayed the action pending arbitration proceedings. Because all claims were subject to arbitration, the court did not consider the defendants’ alternative motion to dismiss or strike, the related evidentiary objections, or the requests for judicial notice. It denied those motions without prejudice as moot. The order did not decide the merits of the plaintiffs’ product-liability, negligence, construction-standard, or unfair-business-practices claims.