Lamps Plus, Inc. v. Varela
United States Supreme Court
139 S. Ct. 1407 (2019)
Frank Varela (plaintiff) had signed an arbitration agreement when he began working for Lamps Plus, Inc. (defendant); after a data breach exposed the tax information of 1,300 Lamps Plus employees and someone filed a fraudulent tax return in Varela's name, Varela brought a putative class action on behalf of all affected employees. Lamps Plus moved to compel individual arbitration, but the trial court ordered class-wide arbitration instead, and the Ninth Circuit, finding the arbitration agreement ambiguous on the class-arbitration question, construed that ambiguity against Lamps Plus as the drafter of an adhesion contract and affirmed class arbitration; Lamps Plus appealed, arguing an ambiguous agreement cannot itself supply the required contractual basis for compelling arbitration on a class-wide basis.
Whether class-wide arbitration requires an unambiguous, affirmative contractual basis showing the parties agreed to it.