Summary
The California Court of Appeal reversed an order denying American Honda Motor Co., Inc. and Standard Motor, LLC’s motion to compel arbitration in a vehicle-defect and warranty dispute. The court held that the appellants met their initial burden of establishing arbitration agreements in the vehicle lease and manufacturer’s warranty booklet, and that the respondent failed to dispute the agreements’ existence with evidence. The matter was remanded with directions to grant the motion to compel arbitration, and the opinion was later certified for publication.
Holdings
- Defendants met their initial burden of establishing the existence of an arbitration agreement with Standard Motor by presenting the signed lease, reciting the arbitration provision verbatim, and relying on Kostandian's judicial admission that Standard Motor did business as Acura of Los Angeles Westside.
- Kostandian failed to dispute the existence of an arbitration agreement with Standard Motor and therefore did not require defendants to make a further evidentiary showing of a valid agreement.
- Defendants met their initial burden of establishing an arbitration agreement between American Honda Motor and Kostandian by producing the warranty booklet, reciting its arbitration provision verbatim, and presenting Kostandian's signed acknowledgment that he received the warranty information.
- The order denying the motion to compel arbitration was reversed, and the trial court was directed to enter an order granting defendants' motion to compel arbitration.
Questions Presented
- Whether defendants established the existence of an arbitration agreement in the vehicle lease with Standard Motor by presenting the signed lease, reciting the arbitration provision, and relying on Kostandian's pleading that Standard Motor did business as Acura of Los Angeles Westside.
- Whether Kostandian disputed the existence of the lease arbitration agreement sufficiently to shift the burden back to defendants to prove a valid agreement.
- Whether defendants established the existence of an arbitration agreement between American Honda Motor and Kostandian through the arbitration provision in the manufacturer's warranty booklet.
- Whether the trial court's denial of the motion to compel arbitration should be reversed.
Disposition
reversed_and_remanded
Cases Cited (13)
- Bono v. David, 147 Cal.App.4th 1055, 1061-1062 (2007)(followed)
- Carlson v. Home Team Pest Defense, Inc., 239 Cal.App.4th 619, 630 (2015)(followed)
- Avila v. Southern California Specialty Care, Inc., 20 Cal.App.5th 835, 843-844 (2018)(followed)
- Baker v. Italian Maple Holdings, LLC, 13 Cal.App.5th 1152, 1160 (2017)(followed)
- Sprunk v. Prisma LLC, 14 Cal.App.5th 785, 793 (2017)(followed)
- Condee v. Longwood Management Corp., 88 Cal.App.4th 215, 219 (2001)(followed)
- Ruiz v. Moss Bros. Auto Group, Inc., 232 Cal.App.4th 836, 845 n.8 (2014)(followed)
- Valerio v. Andrew Youngquist Construction, 103 Cal.App.4th 1264, 1271 (2002)(followed)
- Gamboa v. Northeast Community Clinic, 72 Cal.App.5th 158, 165-166 (2021)(followed)
- Knutson v. Sirius XM Radio Inc., 771 F.3d 559, 561-566 (9th Cir. 2014)(distinguished)
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Court Document
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