Aguilar v. Midas Trucking CA2/7

CourtCalifornia Court of Appeal
DecidedFebruary 13, 2025
DocketB331192
StatusUnpublished

This text of Aguilar v. Midas Trucking CA2/7 (Aguilar v. Midas Trucking CA2/7) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aguilar v. Midas Trucking CA2/7, (Cal. Ct. App. 2025).

Opinion

Filed 2/13/25 Aguilar v. Midas Trucking CA2/7 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION SEVEN

ALEJANDRO AGUILAR et al., B331192

Plaintiffs and Respondents, (Los Angeles County Super. Ct. v. No. 22STCV39767)

MIDAS TRUCKING,

Defendant and Appellant.

APPEAL from an order of the Superior Court of Los Angeles County, Stuart M. Rice, Judge. Affirmed. Ogletree, Deakins, Nash, Smoak & Stewart, Tim L. Johnson, Nikolas T. Djordjevski, Yousaf M. Jafri, and Keenan P. O’Connor for Defendant and Appellant. King & Siegel and Elliot J. Siegel for Plaintiffs and Respondents. ______________________ INTRODUCTION

Midas Trucking appeals from the trial court’s order denying Midas’s motion to compel its former employee Alejandro Aguilar to arbitrate claims arising out of his employment. The court ruled Midas failed to authenticate an electronic signature on an arbitration agreement purportedly presented to Aguilar during the “onboarding” process for new hires. Midas argues the court erred in excluding much of its owner’s declaration detailing the onboarding process and in ruling Midas did not meet its burden with admissible evidence to show the purported signature was Aguilar’s. We conclude that the trial court did not abuse its discretion in excluding most of the owner’s declaration and that the remaining evidence does not compel a decision in favor of Midas. Therefore, we affirm.

FACTUAL AND PROCEDURAL BACKGROUND

A. Aguilar Files This Action Against Midas, and Midas Moves To Compel Arbitration Aguilar worked as a delivery truck driver for Midas from June 2021 to April 2022. In December 2022 Aguilar filed a putative class action, a representative action under the Private Attorneys General Act (PAGA) (Lab. Code, § 2698 et seq.), and individual claims for various Labor Code and related violations. Midas filed a motion to dismiss the putative class action allegations and the PAGA claims and to compel Aguilar to arbitrate his individual claims. The motion was based on an agreement Midas contended showed Aguilar agreed to arbitrate any individual causes of action arising out of or relating to his

2 employment with Midas and waived his right to bring collective actions. Midas submitted a declaration from its owner Michael Ross, who stated he had personal knowledge of the matters in his declaration because he was the owner of the company and had reviewed Midas’s business records and “the onboarding documents that apply to all [Midas] employees.” Ross said that on June 14, 2021 Aguilar “executed an arbitration agreement entitled ‘Mutual Agreement to Individually Arbitrate Disputes.’” Ross attached as exhibit 1 to his declaration an unsigned form agreement with the same title. In his declaration Ross described the company’s “onboarding” process, which generally had prospective employees sign an arbitration agreement and the company’s employee handbook. According to Ross, Midas provides delivery services for Amazon Logistics, Inc., which delivers packages for the online shopping company Amazon. Ross said that, when Midas hires a new driver, Midas “creates a profile for the employee using their name and e-mail address, which causes the onboarding system to send the individual an e-mail.” Ross provided a screenshot of a sample email that suggests the email originated from the “Amazon Logistics Team.” Ross stated the email from Amazon Logistics provides instructions for the new employee to access the onboarding process. There is a link to “Sign in” to create an account. According to Ross, prospective employees must verify their email address using a “unique one-time password that the system sends to their e-mail address, and then the individual sets their own private password.” After creating an account, the prospective employee “receive[s] an invitation to join [Midas] and continue

3 onboarding by clicking on ‘Accept Invitation.’” That action “takes the potential new employee to another page instructing them to download an application to continue with the onboarding process.” The onboarding system refers to the application as the “Amazon Flex app,” and Ross included in his declaration screenshots of the various steps an employee takes while using the Amazon Flex app. To launch the app, the potential employee must enter his or her email address and the password previously used to create an account. The app displays a page consisting of six sections for the employee to complete, including “About You” and “Arbitration Agreement.” When the user selects “Arbitration Agreement,” the app displays an agreement, which the user can scroll through and read. The arbitration agreement states in part: “MANDATORY ARBITRATION. THE EMPLOYEE AND COMPANY AGREE THAT ANY COVERED CLAIM . . . WHETHER BASED IN CONTRACT, TORT, STATUTE, COMMON LAW, FRAUD, MISREPRESENTATION OR ANY OTHER LEGAL OR EQUITABLE THEORY, SHALL BE SUBMITTED TO INDIVIDUAL BINDING ARBITRATION.” “Covered claims” include “all past, current, and future grievances, disputes, claims, issues, or causes of action (collectively, ‘claims’) under applicable federal, state or local laws, arising out of or relating to (a) Employee’s application, hiring, hours worked, services provided, and/or employment with [Midas] or the termination thereof, and/or (b) a [Midas] policy or practice, or [Midas’s] relationship with or to a customer, vendor, or third party, including without limitation claims Employee may have against [Midas] . . . , or that [Midas] may have against Employee.” The agreement also states the employee acknowledges and agrees

4 that “any claims brought by the Employee against” Midas, “whether brought jointly or severally,” “shall be subject to arbitration under this Agreement.” And the agreement includes a waiver of the employee’s right to bring class actions, collective actions, consolidated actions, and representative actions, to the “absolute maximum extent permitted by law.” The agreement states “a court of law must resolve any dispute concerning the validity and enforceability of the Agreement, and the validity, enforceability or interpretation of the provisions pertaining to class, collective, and representative action waivers.” According to Ross, the user must click a box beside the statement “I Agree and Accept” at the end of the arbitration agreement before continuing the onboarding process. The Amazon Flex app then displays a screen showing the six sections of information the potential employee must provide, with the notations “Complete” and a green check mark appearing in the “Arbitration Agreement” section. Ross stated these notations “indicat[e] the individual has electronically accepted” the arbitration agreement. And he said, “No one other than the employee is able to access the employee’s account and accept the Agreement—the employee must do that themselves.” Ross stated Aguilar “accepted the Agreement through the onboarding process by completing the steps above using his own unique username/email, account, and unique, private password.” Attached to Ross’s declaration as exhibit 2 was a document Ross described as “a copy of the on-line record showing the company name, employee name, unique transporter identification number,

5 and date and time [Aguilar] accepted the Agreement.” This is what exhibit 2 says:

According to Ross, “[t]he name ‘ALEJANDRO AGUILAR’ could have only been placed by someone using [Aguilar’s] unique username and password.

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Bluebook (online)
Aguilar v. Midas Trucking CA2/7, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aguilar-v-midas-trucking-ca27-calctapp-2025.