McCallum v. Buckley Law PC

CourtDistrict Court, W.D. Washington
DecidedAugust 9, 2024
Docket3:24-cv-05222
StatusUnknown

This text of McCallum v. Buckley Law PC (McCallum v. Buckley Law PC) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McCallum v. Buckley Law PC, (W.D. Wash. 2024).

Opinion

1 2 3

4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 ARTHUR McCALLUM, CASE NO. C24-05222-KKE 8

Plaintiff, ORDER GRANTING DEFENDANTS’ 9 v. MOTION TO COMPEL ARBITRATION

10 BUCKLEY LAW, P.C., et al.,

11 Defendants.

12 Plaintiff Arthur McCallum retained Defendant Buckley Law, P.C., to represent him in 13 dissolution proceedings. After those proceedings continued for a number of years, McCallum filed 14 an action in Clark County Superior Court, alleging claims against the Buckley firm and individual 15 Buckley lawyers for legal malpractice and breach of fiduciary duty. Dkt. No. 1-2. Defendants 16 removed the case to this Court (Dkt. No. 1) and filed a motion to compel arbitration under the 17 terms of Defendants’ retention agreement with McCallum. Dkt. No. 7. 18 The Court has considered the parties’ briefing and the remainder of the record, and heard 19 oral argument on Defendants’ motion. See Dkt. No. 19. For the reasons below, the Court grants 20 Defendants’ motion to compel arbitration and stays this action pending arbitration. 21

24 1 I. BACKGROUND 2 McCallum signed an Attorney Engagement Agreement (“Agreement”) drafted by 3 Defendants in July 2019. Dkt. No. 9 ¶ 2. It contains the following arbitration clause:

4 All disputes, including claims for negligence, arising out of or related to our relationship is subject to binding arbitration pursuant to the procedural rules of the 5 Arbitration Services of Portland, Inc., and we each waive any other forum or venue. The parties will share equally the cost of the arbitrator and will bear their own fees 6 and expenses related to the arbitration. Because each party is waiving important rights by agreeing to this provision, including a right to a jury trial, you should seek 7 independent advice on whether to waive these rights. This waiver may be revoked up to five (5) business days after execution of this engagement agreement by 8 submitting a revocation to us in writing.

9 Id. at 4. In the paragraph following the arbitration clause, the Agreement instructs: “To confirm 10 the engagement, please countersign this engagement and return a copy to our office as soon as 11 possible with the requested retainer.” Id. McCallum’s signature appears immediately below an 12 acknowledgment that “I have read, understand, and agree to the foregoing terms” at the end of the 13 Agreement. Id. (emphasis omitted). 14 In the present action, where McCallum alleges claims of legal malpractice and breach of 15 fiduciary duty, Defendants request that the Court compel the parties to arbitrate McCallum’s 16 claims and dismiss the suit or, in the alternative, stay the matter pending arbitration. Dkt. No. 7 at 17 9. This motion is now ripe for resolution. 18 II. ANALYSIS 19 A. Legal Standards 20 Written agreements subject to the Federal Arbitration Act (“FAA”), such as the Agreement 21 here1, “shall be valid, irrevocable, and enforceable, save upon such grounds as exist at law or in 22 equity for the revocation of any contract[.]” 9 U.S.C. § 2. The “‘principal purpose’ of the FAA is 23

24 1 The parties agree on this point. See Dkt. No. 7 at 4, Dkt. No. 11 at 4. 1 to ‘ensur[e] that private arbitration agreements are enforced according to their terms.’” AT&T 2 Mobility LLC v. Concepcion, 563 U.S. 333, 344 (2011) (quoting Volt Info. Scis., Inc. v. Bd. of 3 Trustees of Leland Stanford Junior Univ., 489 U.S. 468, 478 (1989)).

4 The court must compel arbitration if (1) a valid and enforceable agreement to arbitrate 5 exists, and if so, (2) the claims at issue fall within the scope of that agreement. Chiron Corp. v. 6 Ortho Diagnostic Sys., Inc., 207 F.3d 1126, 1130 (9th Cir. 2000). Courts apply state contract law 7 formation principles to determine the validity of an arbitration agreement. First Options of 8 Chicago, Inc. v. Kaplan, 514 U.S. 938, 944 (1995). “The party seeking to avoid arbitration has 9 the burden to show that the arbitration clause is unenforceable.” Gandee v. LDL Freedom Enters., 10 Inc., 293 P.3d 1197, 1199 (Wash. 2013). 11 B. The Agreement is a Valid, Enforceable Contract, Including the Arbitration Clause. 12 Defendants ask the Court to compel the parties to arbitrate McCallum’s claims based on

13 the arbitration clause of the Agreement. Dkt. No. 7. McCallum does not dispute that the claims 14 presented in this action fall within the scope of the arbitration clause, but he opposes Defendants’ 15 motion on the basis that the Agreement itself is not a valid contract under Washington law, and 16 even if it is, its arbitration clause is unenforceable because it is unconscionable. Dkt. No. 11. For 17 the following reasons, the Court disagrees with McCallum as to both arguments. 18 1. The Agreement is a Valid Contract Under Washington Law. 19 At the outset, the Court must address whether Oregon or Washington law applies to the 20 Agreement. See Dkt. No. 7 at 5–6 (Defendants’ motion arguing that Oregon law applies, but that 21 the outcome is the same under Washington law), Dkt. No. 11 at 4 (McCallum’s opposition urging 22 the Court to apply Washington law).

23 A federal district court applies the choice of law rules of the state in which it sits. Klaxon 24 Co. v. Stentor Elec. Mfg. Co., 313 U.S. 487, 496 (1941). “[T]here must be an actual conflict 1 between the laws or interests of Washington and the laws or interests of another state before 2 Washington courts will engage in a conflict of laws analysis.” Seizer v. Sessions, 940 P.2d 261, 3 264 (Wash. 1997). “When the result of the issues is different under the law of the two states, there

4 is a ‘real’ conflict.” Id. If there is no real conflict, “the presumptive local law is applied.” Id. 5 Because the Court is not aware of a conflict between Washington and Oregon law material to this 6 dispute, and neither party identifies one, the Court applies Washington law when analyzing the 7 Agreement. 8 The Court now turns to consider McCallum’s first argument, that the Agreement is not a 9 valid contract because it was not fully executed. McCallum asserts that because he alone signed 10 the Agreement, without a countersignature from Defendants, the Agreement does not bind him. 11 Dkt. No. 11 at 8–9. 12 This argument is not persuasive. “Washington courts have routinely rejected the argument

13 that a written agreement lacked mutual consent if not signed by the party seeking to enforce it.” 14 Burgess v. Buddy’s Northwest LLC, No. C15-5785 BHS, 2016 WL 7387099, at *2 (W.D. Wash. 15 Dec. 21, 2016) (citing Shelcon Const. Grp., LLC v. Haymond, 351 P.3d 895, 904 (Wash. Ct. App. 16 2015)). “The proponent of a contract need only prove the existence of the contract and the other 17 party’s objective manifestation of intent to be bound thereby; the unexpressed subjective intent of 18 either party is irrelevant.” Retail Clerks Health & Welfare Trust Funds v. Shopland Supermarket, 19 Inc., 640 P.2d 1051, 1054 (Wash. 1982).

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Related

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First Options of Chicago, Inc. v. Kaplan
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