Arbitration Agreement Was Not Substantively Unconscionable

Santana v. Studebaker Health Care Ctr., LLC, 120 Cal. App. 5^th 1 (2026)

When J. Ascencion Santana was hired by Studebaker Health Care Center, he signed a series of documents, including three that were “arbitration related.” In response to Santana’s subsequent wage and hour putative class action, Studebaker filed a motion to compel arbitration, which the trial court denied based upon various “conflicts” among the three arbitration‑related documents (relating to a waiver of the right to bring a PAGA action). The Court of Appeal reversed, holding that the purported ambiguities among the documents did not undermine the parties’ clear intent to arbitrate notwithstanding some procedural unconscionability (which generally exists with contracts of adhesion). Compare Stoker v. Blue Origin, LLC, 120 Cal. App. 5^th 91 (2026) (arbitration agreement was substantively unconscionable in that it was overbroad, non‑mutual, waived the right to a jury, and contained a class action waiver); see also Jules v. Andre Balazs Properties, 608 U.S. __, 2026 WL 1336216 (2026) (a federal court that has previously stayed claims in a pending arbitration under the FAA retains jurisdiction to confirm or vacate a resulting arbitral award).

Arbitration Agreement Was Not Substantively Unconscionable