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Hamby v. POWER TOYOTA IRVINE

Citations: 798 F. Supp. 2d 1163; 2011 U.S. Dist. LEXIS 77582; 2011 WL 2852279Docket: Case 11cv544-BTM (BGS)

Court: District Court, S.D. California; July 18, 2011; Federal District Court

Narrative Opinion Summary

In this case, the Plaintiff filed an ex parte application to conduct discovery on the issue of unconscionability concerning an arbitration clause and class action waiver in a contract with the Defendant. The Plaintiff argued, under California Civil Code section 1670.5(b), for the right to present evidence on the contract's context and effects, citing past cases that support discovery in arbitration disputes. The Defendant opposed this application, referencing the Supreme Court's decision in AT&T Mobility LLC v. Concepcion, which restricts the application of the Discover Bank rule that previously classified class action waivers as unconscionable. Nevertheless, the Court acknowledged that unconscionability remains a viable defense against arbitration agreements. Consequently, the Court approved the Plaintiff's request for discovery on this matter, assigning Magistrate Judge Skomal to determine its scope and deadlines. Additionally, the motion to compel arbitration was removed from the calendar, with a new hearing date to be set following the completion of discovery. This decision underscores the ongoing judicial balancing act between arbitration enforcement and the protection against unconscionable contract terms.

Legal Issues Addressed

Discovery Related to Unconscionability

Application: The Court allows Plaintiff to conduct discovery regarding the unconscionability of an arbitration clause and class action waiver, referencing California Civil Code section 1670.5(b) and prior case law.

Reasoning: The Court finds support for Plaintiff’s position in prior cases, specifically referencing Coneff v. AT&T Corp., which permits discovery related to unconscionability in arbitration disputes.

Impact of Supreme Court Precedents on Arbitration Clauses

Application: Defendant argues against the unconscionability of the arbitration clause by citing the Supreme Court's decision in AT&T Mobility LLC v. Concepcion, which limits the Discover Bank rule.

Reasoning: Defendant's opposition primarily challenges the merits of Plaintiff's argument regarding the arbitration clause's unconscionability, particularly in light of the Supreme Court's ruling in AT&T Mobility LLC v. Concepcion.

Unconscionability as a Defense Against Arbitration

Application: Despite challenges based on recent Supreme Court rulings, the Court acknowledges unconscionability as a continuing defense against arbitration clauses.

Reasoning: Nonetheless, the Court reiterates that unconscionability remains a valid defense against arbitration.