When Studebaker Health Care Center, Inc. hired J. Asencion Santana, Studebaker required him to sign a series of documents. In three of the documents Studebaker and Santana agreed to arbitrate most disputes arising out of their employment relationship, except for non-individual claims brought as a private attorney general under the Labor Code Private Attorney General Act of 2004 (PAGA; Lab. Code, § 2698 et seq.). After his employment ended Santana filed a wage-and-hour class action against Studebaker, which included a cause of action under PAGA. Studebaker filed a motion to compel arbitration, and the trial court denied it.
Studebaker appeals from the order denying its motion to compel arbitration, arguing the trial court erred in ruling that, because of various “conflicts” among the three arbitration-related documents, there was no valid agreement to arbitrate. Studebaker also argues the trial court erred in ruling in the alternative the agreement to arbitrate was unconscionable and unenforceable.
We agree with Studebaker on both counts. Though the agreement to arbitrate contains a few ambiguities, those ambiguities do not undermine the parties’ clear agreement to arbitrate employment-related disputes. And though the agreement to arbitrate reflects some procedural unconscionability—as contracts of adhesion generally do—the agreement does not contain any substantively unconscionable terms and is not unenforceable. Therefore, we reverse.
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