Garcia v. Central Coast Restaurants, Inc.

Background

The parties raised a dispute about the scope of discovery before a Federal Arbitration Act (FAA) “mini-trial” scheduled for September 19, 2023. The defendants argued that discovery should be limited to facts relevant to the enforceability of three arbitration-agreement versions involved in the case. Jennifer Garcia opposed that limitation.

Ruling

The court held that the defendants’ position was correct. It explained that the mini-trial would address only two questions: whether a valid agreement to arbitrate exists and, if so, whether that agreement covers the dispute. Because enforceability could potentially resolve the case, the court ruled that discovery should not extend to the merits before that issue was decided.

The court ordered that discovery be limited to the enforceability of the arbitration agreements. It directed any discovery disputes concerning that issue to the Magistrate Judge. Under the FAA, the parties also had to indicate by July 19, 2023, whether they intended to request a jury trial for the mini-trial.

The defendants separately argued that merits discovery could risk waiving their right to arbitrate. The court said that concern was misplaced, but considered the issue moot in light of its discovery-limitation order.

Disposition and Effect

Chief Judge Richard Seeborg entered an order limiting discovery. The order addressed discovery and the upcoming arbitration-agreement mini-trial; it did not decide whether the agreements were enforceable or resolve the merits of Garcia’s underlying claims.