Simple Traditions, Inc. v. Paychex, Inc.

CourtDistrict Court, E.D. California
DecidedDecember 3, 2024
Docket2:24-cv-01335
StatusUnknown

This text of Simple Traditions, Inc. v. Paychex, Inc. (Simple Traditions, Inc. v. Paychex, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Simple Traditions, Inc. v. Paychex, Inc., (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 SIMPLE TRADITIONS, INC. and No. 2:24-cv-01335-TLN-SCR NANCY LINN, 12 Plaintiffs, 13 ORDER v. 14 PAYCHEX, INC., 15 Defendant. 16 17 This matter is before the Court on Defendant Paychex, Inc.’s (“Defendant”) Motion to 18 Compel Arbitration. (ECF No. 5.) Plaintiffs Simple Traditions, Inc. (“Simple Traditions”) and 19 Nancy Linn (“Linn”) (collectively, “Plaintiffs”) filed an opposition. (ECF No. 9.) Defendant 20 filed a reply. (ECF No. 11.) For the reasons set forth below, the Court GRANTS Defendant’s 21 motion. 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 1 I. FACTUAL AND PROCEDURAL BACKGROUND 2 The instant action arises of out Defendant’s alleged failure to file employer tax returns and 3 pay payroll taxes for Simple Traditions, a company Linn owns that provides low-cost funeral and 4 cremation services. (ECF No. 1.) Plaintiffs allege that on October 6, 2016, Linn retained 5 Defendant’s services to provide payroll services, to prepare and file employer tax returns, and to 6 pay employer taxes for Simple Traditions. (Id. at 2.) 7 In 2018, Simple Traditions changed its corporate status in California from a “C” 8 corporation to an “S” corporation, which resulted in the Internal Revenue Service’s (“IRS”) 9 issuance of a new Employer Identification Number (“EIN”). (Id. at 2–3.) The old “C” 10 corporation ceased to be effective as of January 1, 2019, when the new EIN became effective. 11 (Id.) In September 2019, Linn informed Defendant’s employee of the change in corporate status, 12 the assignment of a new EIN, and that the new EIN must be used to identify Simple Traditions on 13 all communications with the IRS, including tax returns and employer taxes paid. (Id.) On 14 October 4, 2019, Defendant’s employee acknowledged the change in corporate status and change 15 of EIN and forwarded several forms for Linn to execute and return, which she did. (Id.) 16 In June 2021, Linn retained the services of an accounting firm to determine whether 17 Simple Traditions was eligible to receive Employee Retention Tax Credits (“ERTC”) pursuant to 18 the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”). (Id. at 4.) The firm 19 advised Linn she could receive ERTC refunds of $91,712.58, and Linn retained the firm to apply 20 for the tax credits in the eligible quarters — quarters 2, 3, and 4 in tax year 2020 and quarters 2 21 and 3 in tax year 2021. (Id.) When Linn had not received any contact from the IRS about the 22 status of Simple Traditions’ ERTC application, she made several phone calls to the IRS and 23 learned in March 2022 that the IRS had no record of Simple Traditions’ employer tax returns 24 having been filed or payroll taxes having been paid for tax years 2020 and 2021. (Id.) 25 In March 2023, Linn contacted Defendant’s President’s office, which responded through a 26 client specialist. (Id. at 5.) In April 2023, the client specialist confirmed that not only had 27 Defendant failed to change the EIN in 2019 as Linn instructed, but Defendant misfiled Simple 28 Traditions’ employer tax returns for tax years 2019, 2020, 2021, 2022, and the first quarter of 1 2023 by identifying Simple Traditions under the former now defunct EIN. (Id.) Plaintiffs allege 2 that as a result of Defendant’s admitted errors, the IRS had no record of tax returns for Simple 3 Traditions for the foregoing tax years nor any record of tax payments being made for those years. 4 (Id.) Plaintiffs allege the IRS’s penalties and interest fines total $76,351.00 and are ongoing. 5 (Id.) 6 On May 9, 2024, Plaintiffs filed the instant action, alleging claims for: breach of contract, 7 negligence, gross negligence, and equitable indemnity. (ECF No. 1.) On June 11, 2024, 8 Defendant filed the instant motion to compel arbitration, arguing Linn signed a Paychex 9 Proprietor Services Agreement (the “Agreement”) on behalf of Simple Traditions and the 10 Agreement contains a valid and binding arbitration provision. (ECF No. 5.) 11 II. STANDARD OF LAW 12 In deciding whether to compel arbitration, a district court typically determines two 13 gateway issues: (1) whether a valid agreement to arbitrate exists; and, if it does, (2) whether the 14 agreement encompasses the dispute at issue. Lifescan, Inc. v. Premier Diabetic Servs., Inc., 363 15 F.3d 1010, 1012 (9th Cir. 2004). “To evaluate the validity of an arbitration agreement, federal 16 courts ‘should apply ordinary state-law principles that govern the formation of contracts.’” Ingle 17 v. Circuit City Stores, Inc., 328 F.3d 1165, 1170 (9th Cir. 2003) (citing First Options of Chicago, 18 Inc. v. Kaplan, 514 U.S. 938, 944 (1995)). If the court is “satisfied that the making of the 19 arbitration agreement or the failure to comply with the agreement is not in issue, the court shall 20 make an order directing the parties to proceed to arbitration in accordance with the terms of the 21 agreement.” 9 U.S.C. § 4. “[A]ny doubts concerning the scope of arbitrable issues should be 22 resolved in favor of arbitration.” Moses H. Cone Mem’l Hosp. v. Mercury Constr. Corp. (Moses 23 H. Cone), 460 U.S. 1, 24–25 (1983). If a court “determines that an arbitration clause is 24 enforceable, it has the discretion to either stay the case pending arbitration, or to dismiss the case 25 if all of the alleged claims are subject to arbitration.” Hoekman v. Tamko Bldg. Prod., Inc., No. 26 2:14-cv-01581-TLN-KJN, 2015 WL 9591471, at *2 (E.D. Cal. Aug. 26, 2015) (citation omitted). 27 There is an “emphatic federal policy in favor of arbitral dispute resolution.” Mitsubishi 28 Motors Corp. v. Soler Chrysler–Plymouth, 473 U.S. 614, 631 (1985). As such, “‘any doubts 1 concerning the scope of arbitrable issues should be resolved in favor of arbitration, whether the 2 problem at hand is the construction of the contract language itself or an allegation of waiver, 3 delay, or a like defense to arbitrability.’” Id. at 626 (quoting Moses H. Cone, 460 U.S. 1 at 24– 4 25). “Because waiver of the right to arbitration is disfavored, ‘any party arguing waiver of 5 arbitration bears a heavy burden of proof.’” Fisher v. A.G. Becker Paribas Inc., 791 F.2d 691, 6 694 (9th Cir. 1986) (quoting Belke v. Merrill Lynch, Pierce, Fenner & Smith, 693 F.2d 1023, 7 1025 (11th Cir. 1982), abrogated on other grounds by Dean Witter Reynolds, Inc. v. Byrd, 470 8 U.S. 213 (1985)). Therefore, an arbitration agreement may only “be invalidated by ‘generally 9 applicable contract defenses, such as fraud, duress, or unconscionability,’ but not by defenses that 10 apply only to arbitration or that derive their meaning from the fact that an agreement to arbitrate 11 is at issue.” AT&T Mobility LLC v. Concepcion, 563 U.S. 333, 343–44 (2011) (quoting Doctor’s 12 Associates, Inc. v. Casarotto, 517 U.S. 681, 687 (1996)). Courts may not apply traditional 13 contractual defenses, like duress and unconscionability, in a broader or more stringent manner to 14 invalidate arbitration agreements and thereby undermine FAA’s purpose to “ensur[e] that private 15 arbitration agreements are enforced according to their terms.” Id. at 1748 (quoting Volt Info. 16 Scis., Inc. v. Bd.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

McIlvaine v. Coxe's Lessee
8 U.S. 209 (Supreme Court, 1808)
First Options of Chicago, Inc. v. Kaplan
514 U.S. 938 (Supreme Court, 1995)
Doctor's Associates, Inc. v. Casarotto
517 U.S. 681 (Supreme Court, 1996)
Bunch v. W.R. Grace & Co.
555 F.3d 1 (First Circuit, 2009)
Kilgore v. KeyBank, National Ass'n
673 F.3d 947 (Ninth Circuit, 2012)
Peng v. First Republic Bank CA1/1
219 Cal. App. 4th 1462 (California Court of Appeal, 2013)
Zenia Chavarria v. Ralphs Grocery Company
733 F.3d 916 (Ninth Circuit, 2013)
Lewis v. UBS Financial Services Inc.
818 F. Supp. 2d 1161 (N.D. California, 2011)
Stirlen v. Supercuts, Inc.
51 Cal. App. 4th 1519 (California Court of Appeal, 1997)
Armendariz v. Found. Health Psychcare Servs., Inc.
6 P.3d 669 (California Supreme Court, 2000)

Cite This Page — Counsel Stack

Bluebook (online)
Simple Traditions, Inc. v. Paychex, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/simple-traditions-inc-v-paychex-inc-caed-2024.