Aguila v. Becton and Dickinson
- Edward Davila
- 5:22-cv-06670
- U.S. District Court · Northern District of California
- 10
Aguila v. Becton and Dickinson: Judge Davila denied arbitration and class-claim dismissal because the arbitration provision was unenforceable under California law.
Ramon Aguila and the proposed class were affected because the court denied the defendants’ requests to compel arbitration of Aguila’s individual claims and dismiss the class claims. Becton Dickinson and Apidel were the defendants whose motion was denied.
What happened
In Aguila v. Becton and Dickinson, Ramon Aguila brought an employment lawsuit alleging violations of California wage-and-hour laws. The defendants asked the court to require arbitration of his individual claims and dismiss his proposed class claims.
The court found that Aguila’s agreement required arbitration in Chicago even though he lived and worked in California. It ruled that this requirement conflicted with California public policy and that the arbitration provision was both unfairly one-sided and presented on a take-it-or-leave-it basis without providing the arbitration rules.
Judge Davila denied the defendants’ motion to compel arbitration and dismiss Aguila’s class claims. Because the provision was unenforceable, the court did not decide the defendants’ other arguments about the provision’s scope, Becton Dickinson’s authority to compel arbitration, or arbitration of class claims.
The detailed version
- Aguila v. Becton and Dickinson · No. 5:22-cv-06670
- Edward Davila
- Sept. 13, 2023
Background
Ramon Aguila sued Becton Dickinson and Company and Apidel Technologies, LLC, individually and on behalf of a proposed class. He alleged that the defendants violated California’s Labor Code and Business and Professions Code by failing to pay required overtime and minimum wages, provide meal and rest breaks, pay premiums for missed meal breaks, compensate pre-shift work, reimburse business expenses, provide reporting-time pay, and provide sufficient wage statements.
Before his employment, Aguila signed an Employee Consulting Project Acceptance Agreement with Apidel. The agreement stated that disputes arising from or relating to the agreement would be governed by the American Arbitration Association’s Model Employment Arbitration Procedures and settled by final and binding arbitration in Chicago, Illinois. The agreement assigned Aguila to work on a Becton Dickinson project in San Jose, California, listed San Jose as his address, and was signed by Aguila and Apidel, but not Becton Dickinson.
The defendants jointly moved under the Federal Arbitration Act to compel arbitration of Aguila’s individual claims and dismiss his class claims. The court also took judicial notice of a related state-court order involving the same parties and agreement.
Court’s Analysis
The court applied California contract-formation principles to determine whether the arbitration provision was enforceable. It held that the requirement to arbitrate in Chicago conflicted with California’s strong public policy against requiring employees who primarily live and work in California to resolve California employment claims outside the state. The court therefore found the provision unlawful and unenforceable.
The court also found both types of unconscionability recognized under California law. Substantive unconscionability means that a contract term is unjustifiably one-sided; the court found that requiring Aguila to arbitrate outside California imposed too great a burden. Procedural unconscionability concerns how the agreement was presented and whether there was oppression or surprise. The court found procedural unconscionability because the agreement was presented on a take-it-or-leave-it basis, placed the arbitration provision discreetly among other provisions under “Signature Acknowledgement,” and did not provide the arbitration rules or direct Aguila to where he could find them.
Because the court found both substantive and procedural unconscionability, it declined to enforce the arbitration provision. The court did not reach the defendants’ additional arguments about the provision’s scope, Becton Dickinson’s authority to compel arbitration, or whether class claims could be arbitrated.
Disposition
Judge Edward J. Davila denied the defendants’ motion to compel arbitration and dismiss Aguila’s class claims. The opinion does not state that the court dismissed any claims or otherwise resolve the underlying wage-and-hour claims.
Read the full 10-page opinion on CourtListener, the free public archive maintained by the Free Law Project.