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Judge H. Lee Sarokin

Judge H. Lee Sarokin

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Supreme Court Rules That Small Claims Cannot Be Pursued Against Big Corporations

Posted: 05/15/11 08:10 PM ET

In all fairness, that is not exactly what the Supreme Court actually ruled, but that certainly is the effect of the ruling. The Court held that a suit which involved individual claims of $30.22 against AT&T Mobility could not proceed as a class action because the claimants had each agreed to arbitrate any disputes with the company. In reality, absent the vehicle of a class action, no one was going to pursue a claim for $30.22. So in the face of the millions of arbitration clauses that appear in all types of purchase, licensing and similar agreements (unbeknownst to consumers) their chance of recovering small claims has been effectively barred. No individual is going to spend the time and money to pursue such a claim in arbitration.

Companies that do not have such clauses in their purchase or licensing agreements will certainly include them now. Raise your hand if you have ever read the agreement you sign with your telephone company or the licensing agreement you accept with your software. Consumers are totally at the mercy of the companies with whom they deal. Arbitration, indeed, makes good sense in many instances, but not where it is utilized to defeat claims, particularly such as the ones asserted here based upon fraud and false advertising.

There has been some valid criticism of past class action abuses, but the very purpose of class actions was to permit persons to join together in situations such as this in which their individual claims were not worth pursuing or it was too expensive or difficult to do so. Although I have no knowledge as to the merits of the claims asserted here, in rendering this decision, the Supreme Court has permitted alleged corporate fraud to go unheard and unpunished and, in turn, has silenced the voice of the consumer in the process.

 
In all fairness, that is not exactly what the Supreme Court actually ruled, but that certainly is the effect of the ruling. The Court held that a suit which involved individual claims of $30.22 agains...
In all fairness, that is not exactly what the Supreme Court actually ruled, but that certainly is the effect of the ruling. The Court held that a suit which involved individual claims of $30.22 agains...
 
 
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HUFFPOST SUPER USER
katylab
cops have the best dope
01:55 AM on 05/26/2011
The Supreme Court of the United States - a wholly owned subsidiary of Big Business.
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12:48 AM on 05/20/2011
"The Court held that a suit which involved individual claims of $30.22 against AT&T Mobility could not proceed as a class action because the claimants had each agreed to arbitrate any disputes with the company."

No, that's not quite what they ruled either. The class action was blocked because the contract contained a clause that required that claims could only be brought in an “individual capacity, and not as a plaintiff or class member in any purported class or representative proceeding.", according to the contract language quoted by Justice Scalia in his opinion. The California Supreme Court had previously ruled that a clause prohibiting class arbitration was unconscionable. The Court held that the state court was preempted from making this ruling by the Federal Arbitration Act.

It is not relevant to the case, but Justice Scalia pointed out some rather unusual features of the AT&T Mobility arbitration clause. According to him:
"In the event the parties proceed to arbitration, the agreement specifies that AT&T must pay all costs for nonfrivolous claims; that arbitration must take place in the county in which the customer is billed; ... and that the arbitrator may award any form of individual relief, including injunctions and presumably punitive damages. The agreement... in the event that a customer receives an arbitration award greater than AT&T’s last written settlement offer, requires AT&T to pay a $7,500 minimum recovery and twice the amount of the claimant’s attorney’s fees."
nothingchanges
too soon old, too late smart
02:30 PM on 05/18/2011
How many people actually read those "terms of acceptance" contracts that we all have to check the box on to use a software product?

How many people could actually understand them if they read them?

Ignorance of the law is no excuse......................creates a legal system where only the lawyers or those with the money to hire them, have even the vaguest of notions of what a legal contract says, and even they can't agree on it most of the time.

Our system of government, and our system of morals is broken. Look to the people that profit from a "broken system" and you will see why.

Right and wrong no longer even matter, it's what's legal or illegal that governs.
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HUFFPOST SUPER USER
Robert Cantor
I am a human being descended from an exclusive gro
06:06 PM on 05/18/2011
and if people read them, what wold their alternative be? Get a Credit Card or a service that did not demand such arbitration?
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HUFFPOST SUPER USER
Robert Cantor
I am a human being descended from an exclusive gro
09:10 PM on 05/17/2011
ty for your comments, Mr. Sarokin
Romans1 - Christians 0
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TheCommons
I didn't quit. You just bored me.
07:15 PM on 05/17/2011
We have been for the past 30 years in a very corporate friendly political environment. That has brought us a 30 year anti-consumer movement in our legislatures and courts.
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HUFFPOST SUPER USER
Mr Sick Of Greed
05:42 PM on 05/17/2011
we live in a democracy of hypocrisy.....
03:12 PM on 05/17/2011
A possible state legislative solution could be to empower small claims courts, which in many jurisdictions act via arbitrators rather than through formal court process, to have arbitration jurisdiction under any agreement that requires arbitration. I once drafted a state statutory provision that permitted the purchase of an Index Number in a state court to provide sufficient nexus to treat a non-judicial foreclosure as a judicial foreclosure for the purpose of cutting off federal tax liens. While the statute has passed its sunset clause and is no longer in force, the provision was never challenged.
09:28 AM on 05/17/2011
The true tragedy in this case is that if people could get beyond their visceral hatred of corporations this should have been a 9-0 ruling in ATT's favor

1) If there is a conflict because of the Preemption Clause the FAA will trump state contract law.
2) The FAA mandates upholding arbitation agreements-of all variety- in contracts unless there is a contract defense which is generally applicable.
3) Such generally applicable defenses are fraud, duress and in this case, unconscionability.
4) Thus no one debates that if a state strictly outlawed arbitration agreements that the FAA would override this.
5) In California historically to show unconscionability you needed to show both procedural and sunstantive unconscionability. The former would be satisfied by certain contracts of adhesion like ATTs, while the latter usually required some result that "shocked the conscience".
6) A $30.22 injustice would almost certainly fail the latter requirement.
7) However, about 5 years ago in the Discover Bank case California got cute and invalidated- under the guise of unconscionability- consumer agreements with class action waivers that involved small sums.
8) Technically, the Discover Bank rule didn't apply to just arbitration waivers-it also applied to class action lawsuit waivers- but it clearly didn't flow from the historical principles of unconscionability in California. Although California is free to carve at new defenses, under the FAA it can't disfavor arbitration agreements. Because the "Discover Bank" rule was essentially tailor-made for such agreements it did just that.
apiazza
There is no such thing as a fiscal conservative.
12:36 PM on 05/18/2011
Thanks for clearing that up for us.
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joebaggadonuts
Civilization: Evolutionary pathway of choice.
09:29 PM on 05/16/2011
In most states there is a small claims court. For a modest fee you can file a case against any company. Often they just don't show and you can have a judgement for a minor amount; perhaps 500 dollars or maybe a few thousand (whatever the limit of the local small claims court is), which you can add to the 30 dollars to get their attention and which might just be awarded if they fail to show.

I am not sure I would recommend this because if it happens often enough, AT&T will change the arbitration clause to include something like ... if you sue us in small claims court on a matter which should have been arbitrated, and a decision by such court is eventually overturned, you agree to pay all our attorney's fees in reaching such conclusion - and they might just make examples of a few folks who do this.

So, yes, even the relief valve of individual action is unlikely to help.

The goal of the shadow elite has been to make the cost of legal redress available only to the very wealthy, i.e., themselves. They have succeeded.

Your article is appreciated.

If we ever get to have representatives elected by the people again or fair representation on the Supreme Court again, things may change. Otherwise revolution is the only remaining redress, and despite our second amendment rights, we are hopelessly outgunned.
HUFFPOST SUPER USER
mdlawyer2
01:30 PM on 05/17/2011
Small claims court isn't even available. Pursuant to the contract clause (and the S.C.'s ruling) ALL disputes must be settled by arbitration, the consumer having waived their rights to litigation.
HUFFPOST SUPER USER
dctackett
06:59 PM on 05/16/2011
then we make class action lawsuits override any arbitration agreement... update the law.

didn't say it would be easy... but take class action...
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HUFFPOST SUPER USER
bkerensa
Evangelist at Ubuntu
06:39 PM on 05/16/2011
I thought this article was about Small Claims Court.... Small Claims Court is a joke as well because certain things must be handled in Small Claims Court yet in Small Claims you cannot have an attorney and cannot appeal a decision.

No justice at all in Small Claims.
05:48 PM on 05/16/2011
Is this really just a "Big Corporations" issue? Don't businesses of all sizes have purchase or licensing agreements? Effective planning is crucial for any business; entrepreneurs and companies of all sizes need to use whatever tools they have available to them.

So, what is there to keep businesses honest?

How about the knowledge that customers are essential for business success. No customers = no business. Period.

As long as there is enough real competition out there, maybe litigation and arbitration can be avoided. Smart consumers will find the good companies out there, and tell people about it. Smart companies will adapt to consumer needs, or be replaced by a company who can.

The real question is can we separate business and politics to allow that to happen?
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Peter Combs
Amused by the illogical..no, NOT a Republican
05:13 PM on 05/16/2011
The ruling said :

"The revised agreement provides that customers may initiate dispute proceedings by completing a one-page No-tice of Dispute form available on AT&T’s Web site. AT&T may then offer to settle the claim; if it does not, or if the dispute is not resolved within 30 days, the customer may invoke arbitration by filing a separate Demand for Arbitration, also available on AT&T’s Web site. In the event the parties proceed to arbitration, the agreement specifies that AT&T must pay all costs for nonfrivolous claims; that arbitration must take place in the county in which the customer is billed; that, for claims of $10,000 or less, the customer may choose whether the arbitration proceeds in person, by telephone, or based only on submissions; that either party may bring a claim in small claims court in lieu of arbitration; and that the arbitrator may award any form of individual relief, including injunctions and presumably punitive damages. The agreement, moreover, denies AT&T any ability to seek reimbursement of its attorney’s fees, and, in the event that a customer receives an arbitration award greater than AT&T’s last written settlement offer, requires AT&T to pay a $7,500 minimum recovery and twice the amount of the claimant’s attorney’s fees. 3"

How much did these folks plan on making off of $30.00. Small Claims court is also allowed under the agreement.
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joebaggadonuts
Civilization: Evolutionary pathway of choice.
09:35 PM on 05/16/2011
Please provide a link to the revised agreement.

"...the customer may invoke arbitratio­n by filing a separate Demand for Arbitratio­n, also available on AT&T’s Web site. ..."

Still, if T loses the demand... what's the recourse then?

Would also like to see who the arbitrators are and how they get selected/paid/graded/career path - i.e., grounds for bias in decision making.
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Peter Combs
Amused by the illogical..no, NOT a Republican
11:33 PM on 05/16/2011
The paragraph is a direct quote from the Supreme Court Decision....its on the Cornell Law Site...

Here is a link..
http://www.law.cornell.edu/supct/html/09-893.ZO.html
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Peter Combs
Amused by the illogical..no, NOT a Republican
04:05 PM on 05/16/2011
That is not what the ruling said at all. Its said if you sign an agreement to abide by Arbitration, then thats the deal..

As far as I know, no consumer giveaway includes paying the sales tax on the item. If you win a car, you pay income taxes and sales taxes on the car, the same goes for Free Airline Tickets which are taxable form an income tax standpoint as well as sales taxes.
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HUFFPOST BLOGGER
Judge H. Lee Sarokin
Retired after serving 17 years on the federal cour
05:11 PM on 05/16/2011
Peter - True, but in doing so it rejected the ruling of the 9th Circuit which held that under California law arbitration is no substitute for class action remedies. The company can certainly assume the obligation to pay taxes when offering something "free". But if arbitration is the only route available---the fraud alleged will never be determined for most if not all of the claimants.
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Peter Combs
Amused by the illogical..no, NOT a Republican
11:44 PM on 05/16/2011
Yes of course, but they also pointed out that California law is Pre Empted by the broader Federal law taking priority over state laws.

If the State felt this was a legitamet case of fraud the California AG's office could have brought fraud charges based on any one or several of the existing consumer laws to bear against AT&T. WHich could have resulted in fines and demands of reimbursement to those affected following a conviction on criminal charges. In this scenario, the FAA would have no bearing, as the "Victims" are not the subject of the case but is instead focussed on Criminal Fraud.

The Supreme Court also pointed out that the plaintiffs had a better chance at a remedy via Arbitration or under the Ammended Agreement Small Claims court. The California Superior court agreed on this point as well.

All of this said, the California AG's office could bring criminal charges if their was a legitatmet case of fraud which would not be subject to the FAA requirement. Is interesting that they did not.
04:00 PM on 05/16/2011
This ruling isn't anti consumer it is anti-lawyer. Lawyers being the number one special interest of the Democrat party it isn't a huge surprise that they are defended. You know since we all NEED class action law suits to help us with $30 bills. Those lawyers fighting those cases are really on OUR side. Right...
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HUFFPOST BLOGGER
Judge H. Lee Sarokin
Retired after serving 17 years on the federal cour
05:30 PM on 05/16/2011
AustinG - A number of the comments suggest that class actions result in small payments to the claimants and large payments to the lawyers. That may be true, but I have seen many cases in which class actions have resulted in large payments to claimants as well. Without lawyers willing to risk their time and money many of these cases would not proceed. No one is going to pursue a claim in arbitration or even small claims court for $30. Absent a class action in this type of case and similar ones, a company (assuming it may be guilty of fraud and false advertising) would reap the benefits of its misconduct. Class actions for discrimination may not provide large awards for the claimants, but they serve an important purpose and should be encouraged. All fees in class action cases are subject to court approval and are frequently contested. Given the choice I would rather see the lawyers paid handsomely rather than have the companies go unpunished for misconduct.
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Peter Combs
Amused by the illogical..no, NOT a Republican
06:01 PM on 05/16/2011
"would reap the benefits of its misconduct"

What benefits? They do not keep the sale's tax money...they turn it in to the state. I am at a loss to understand what the "misconduct" could be in this case.

The last time I checked a company has no power to negate state laws regarding sales tax collection. If they pay the sales tax, it is then taxable to the beneficiary...If you win a car, you pay the sales tax, excise tax and income tax on the gain, even though the car itself was in fact FREE.
In this case the Phone was free...not tax exempt.