Tuufuli v. West Coast Dental Administrative Services, LLC

Summary

The California Court of Appeal affirmed an order compelling arbitration of Sinedou S. Tuufuli’s individual employment claims against West Coast Dental Administrative Services, LLC and dismissing her class claims. The court held that the Federal Arbitration Act governed the arbitration agreement because the parties expressly agreed that it would apply, without deciding whether the underlying employment transaction independently involved interstate commerce.

Holdings

1. Parties may voluntarily elect to have the Federal Arbitration Act govern enforcement of their arbitration agreement, and an express provision stating that the agreement is governed by the FAA is sufficient to establish that contractual choice.
2. The order compelling arbitration of Tuufuli's individual claims and dismissing her class claims was proper under the parties' arbitration agreement.

Questions Presented

1. Whether the parties' arbitration agreement could be governed by the Federal Arbitration Act because the agreement expressly stated that the FAA governed it, even apart from a determination that the underlying transaction involved interstate commerce.
2. Whether the trial court properly compelled arbitration of Tuufuli's individual claims and dismissed her class claims under the arbitration agreement.

Disposition

affirmed