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Circuit City Stores, Inc. v. Ahmed

United States Court of Appeals, Ninth Circuit
Mar 22, 2002
283 F.3d 1198 (9th Cir. 2002)

Summary

holding arbitration agreement enforceable based on employee's failure to opt-out within the 30-day window

Summary of this case from Needleman v. Golden 1 Credit Union

Opinion

No. 98-55896.

Argued and Submitted September 26, 2001.

Filed March 22, 2002.

Andrew M. Wyatt, Woodland Hill, CA, for the respondent-appellant.

Rex Darrell Berry, Davis, Grimm Payne, Seattle, WA, for the petitioner-appellee.

On Remand from the United States Supreme Court.

Before B. FLETCHER, D.W. NELSON, and BRUNETTI, Circuit Judges.


OPINION


The Supreme Court vacated this Court's prior decision in this case and remanded for proceedings in accordance with its opinion in Circuit City Stores, Inc. v. Adams, 532 U.S. 105, 121 S.Ct. 1302, 149 L.Ed.2d 234 (2001). This case in its current posture raises issues identical to those we addressed on remand in Adams, 279 F.3d 889(9th Cir. 2002), except that the arbitration agreement at issue in this case allowed employees a meaningful choice not to participate in the program. We find this difference — the genuine possibility to opt-out of the arbitration program — to be dispositive and therefore affirm.

I. FACTUAL AND PROCEDURAL BACKGROUND

In March 1995, Mohammad Sharfuddin Ahmed began working as a sales counselor at Circuit City. A month later, Circuit City instituted an "Associates Issue Resolution Program" that included a provision calling for "binding arbitration of legal disputes." On April 4, 1995, Ahmed signed an "Associate Receipt of Issue Resolution Package" form. The package contained (1) an Associate Issue Resolution Handbook, (2) the Circuit City Dispute Resolution Rules and Procedures, and (3) a Circuit City "Opt-Out" Form. If Ahmed did not mail the opt-out form to Circuit City within 30 days, the materials indicated in several places that Ahmed would be "automatically part of the arbitration program" and "required to arbitrate all employment related legal disputes" with Circuit City. If Ahmed had decided to opt-out of the arbitration program, he would have been allowed to keep his job and not participate in the program. Ahmed did not mail in the opt-out form.

On December 15, 1997, Ahmed filed a state court lawsuit against Circuit City and three co-workers under the California Fair Employment and Housing Act ("FEHA"), Cal. Gov't Code § 12900 et seq. Circuit City sought mutually binding arbitration under Section 4 of the FAA. On April 6, 1998, the district court below filed an order staying Ahmed's state court action and compelling arbitration, from which Ahmed appealed. We reversed on the ground that Ahmed's employment contract was exempted from the FAA's coverage based on Craft v. Campbell Soup Co., 177 F.3d 1083 (1999). The Supreme Court granted certiorari, vacated our decision, and remanded for further consideration in light of its decision in Adams. See Circuit City Stores, Inc. v. Ahmed, 532 U.S. 938, 121 S.Ct. 1399, 149 L.Ed.2d 342 (2001).

II. DISCUSSION

This case raises identical issues to those we addressed in Circuit City v. Adams, No. 98-15992, with one important difference: in this case, Ahmed was given a meaningful opportunity to opt out of the arbitration program.

An agreement to arbitrate is unconscionable only if it is both procedurally and substantively unconscionable. Armendariz v. Found. Health Psychcare Servs., Inc., 24 Cal.4th 83, 99 Cal.Rptr.2d 745, 6 P.3d 669, 690 (2000). In Adams, we found that the agreement was procedurally unconscionable because it was a contract of adhesion. By contrast, this case lacks the necessary element of procedural unconscionability. Ahmed was not presented with a contract of adhesion because he was given the opportunity to opt-out of the Circuit City arbitration program by mailing in a simple one-page form. Moreover, and apart from its non-adhesive nature, the arbitration agreement here also lacked any other indicia of procedural unconscionability. The terms of the arbitration agreement were clearly spelled out in written materials and a videotape presentation; Ahmed was encouraged to contact Circuit City representatives or to consult an attorney prior to deciding whether to participate in the program; and he was given 30 days to decide whether to participate in the program.

Ahmed argues that he was not given a meaningful opportunity to opt out of the arbitration program because he did not have the degree of sophistication necessary to recognize the meaning of the opt-out provision or to know how to avoid it, and because 30 days was too short a period in which to make a decision because "an employee is thinking positively about the employment relationship in the first 30 days." Ahmed cites no cases in support of these arguments. Moreover, the general rule is that "one who signs a contract is bound by its provisions and cannot complain of unfamiliarity with the language of the instrument." Madden v. Kaiser Found. Hosps., 17 Cal.3d 699, 131 Cal.Rptr. 882, 552 P.2d 1178, 1185 (1976). Ahmed was given ample opportunity to investigate any provisions he did not understand before deciding whether to opt out of Circuit City's arbitration program.

Because Ahmed fails to satisfy even the procedural unconscionability prong, we need not reach his arguments that the agreement is substantively unconscionable.

III. CONCLUSION

Based on the foregoing, the district court's order staying the state court proceeding and compelling arbitration is

AFFIRMED.


Summaries of

Circuit City Stores, Inc. v. Ahmed

United States Court of Appeals, Ninth Circuit
Mar 22, 2002
283 F.3d 1198 (9th Cir. 2002)

holding arbitration agreement enforceable based on employee's failure to opt-out within the 30-day window

Summary of this case from Needleman v. Golden 1 Credit Union

holding that procedural unconscionability did not exist when plaintiff "was given the opportunity to opt-out of the Circuit City arbitration program by mailing in a simple one-page form"

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finding an arbitration clause was not a contract of adhesion because plaintiff "was given the opportunity to opt-out of the Circuit City arbitration program by mailing . . . a form"

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finding no procedural unconscionability when plaintiff was given thirty days to decide whether to participate in the arbitration program and mail a simple form to opt out, and the arbitration agreement did not contain any other indicia of procedural unconscionability

Summary of this case from Mohammad v. T-Mobile United States, Inc.

finding no procedural unconscionability where there was a thirty-day period to consider whether to opt out of arbitration

Summary of this case from Jenkins v. Sterling Jewelers, Inc.

finding no contract of adhesion or procedural unconscionability where employer provided 30–day opt-out option from arbitration program

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finding no procedural unconscionability where plaintiff was given thirty days to decide whether to participate in the arbitration program and mail a simple form to opt-out, and the arbitration agreement did not contain any other indicia of procedural unconscionability

Summary of this case from Meyer v. T-Mobile USA Inc.

finding no procedural unconscionability when the plaintiff was given the opportunity to opt out of the arbitration agreement

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concluding that an arbitration clause was procedurally conscionable because there was a 30-day opt-out period

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concluding that employee had a meaningful opportunity to opt out where he could mail in opt out form within 30 days of signing agreement

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affirming an order compelling arbitration of an FEHA claim when no claim was brought under Title VII

Summary of this case from Circuit City Stores, Inc. v. Najd

affirming order to enforce arbitration clause providing employees with thirty days to decide to opt-out

Summary of this case from Hose v. Wash. Inventory Servs., Inc.

rejecting unconscionability challenge because employee acknowledged the agreement in writing and had a fair chance to review its terms

Summary of this case from Circuit City Stores, Inc. v. Najd

rejecting argument that arbitration agreement was procedurally unconscionable when plaintiff asserted he "did not have the degree of sophistication necessary to recognize the meaning of the opt-out provision or to know how to avoid it."

Summary of this case from Knepper v. Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

In Circuit City Stores, Inc. v. Ahmed, 283 F.3d 1198, 1199–1200 (9th Cir.2002), we applied California law and determined that an arbitration agreement was not procedurally unconscionable, in large part because it contained an opt-out provision allowing the plaintiff to reject the arbitration program within 30 days of signing the contract.

Summary of this case from Kilgore v. KeyBank, Nat' Ass'n

enforcing an arbitration agreement that was substantively unconscionable but lacked procedural unconscionability

Summary of this case from Ingle v. Circuit City Stores, Inc.

allowing compulsory arbitration of FEHA claims where agreement was not unconscionable

Summary of this case from Equal Emp't Opportunity Comm'n v. Luce, Forward, Hamilton, & Scripps

In Ahmed, the Ninth Circuit found no procedural unconscionability in a situation similar to the one presented here, where the employer instituted an arbitration program, sent an information package about the program to its employees, and provided a 30-day window for employees to opt out of the program.

Summary of this case from Paxton v. Macy's W. Stores, Inc.

In Ahmed, Kilgore, and Uber, the availability of a meaningful opt out procedure, even if limited in time, caused the agreements to not be procedurally unconscionable.

Summary of this case from Bradford v. Flagship Facility Servs. Inc.

In Circuit City Stores, Inc. v. Ahmed, 283 F.3d 1198 (9th Cir. 2002), the Ninth Circuit held that an arbitration agreement with an opt-out provision was not procedurally unconscionable.

Summary of this case from Bradford v. Flagship Facility Servs. Inc.

applying California law and concluding that “Ahmed was not presented with a contract of adhesion because he was given the opportunity to opt-out of the Circuit City arbitration program by mailing in a simple one-page form”

Summary of this case from Mohamed v. Uber Techs., Inc.

providing thirty-day opt out period by mailing one-page form

Summary of this case from O'Connor v. Uber Technologies, Inc.

In Ahmed, the Court of Appeals for the Ninth Circuit held that an employer's arbitration agreement was not procedurally unconscionable when the employee "was given a meaningful opportunity to opt out," because he was given an opportunity to opt out of the arbitration program by mailing a one-page form within thirty days.

Summary of this case from Velazquez v. Sears, Roebuck & Co.

declining to inquire into substantive unconscionability after finding no procedural unconscionability

Summary of this case from Coppock v. Citigroup, Inc.

In Circuit City Stores, Inc. v. Ahmed, 283 F.3d 1198, 1199-1200 (9th Cir. 2002), the Ninth Circuit Court of Appeals found that an arbitration agreement containing a similar opt out provision, was not procedurally unconscionable.

Summary of this case from Hodsdon v. Bright House Networks, LLC
Case details for

Circuit City Stores, Inc. v. Ahmed

Case Details

Full title:CIRCUIT CITY STORES, INC., a Virginia corporation, Petitioner-Appellee, v…

Court:United States Court of Appeals, Ninth Circuit

Date published: Mar 22, 2002

Citations

283 F.3d 1198 (9th Cir. 2002)

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