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