Appeals Court Affirms Enforceability of Arbitration Clause in Auto Service Contract
A New Jersey appeals court on Thursday overturned a trial judge's decision not to dismiss a putative class action targeting the service contract signed by the plaintiff when he bought a used pickup truck.
May 18, 2018 at 02:31 PM
3 minute read
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A New Jersey appeals court on Thursday overturned a trial judge's decision not to dismiss a putative class action targeting the service contract signed by the plaintiff when he bought a used pickup truck.
Appellate Division Judges Harry Carroll and Hany Mawla, in an unpublished ruling, said the trial judge should have granted the motion by the defendant, GWC Warranty Corp., to dismiss the lawsuit, filed by plaintiff Joseph Signor.
“Arbitration agreements should be read liberally and in favor of arbitration,” the court said in a per curiam opinion.
The court distinguished the U.S. Court of Appeals for the Third Circuit's 2017 decision in Noble v. Samsung: “The arbitration provision in Noble was found on page 97 of a 143-page contract. … Here, the service contract instructs consumers to look within it for significant terms, is only 11 pages in length, and the words 'Arbitration Provision' appear in capitalized, bold, and underlined letters.”
According to the court, the case began in 2015, when Signor purchased a used 2003 Ford F-250 from 123 Auto Sales in Branchville, Somerset County. At the same time, he purchased a $916 service contract from GWC, based in Wilkes-Barre, Pennsylvania. The contract was supposed to cover basic repairs for 180 days of 7,500 miles, whichever came first.
It is unclear why Signor filed a lawsuit against GWC, but he did, alleging violations of the state's Consumer Fraud Act and the Truth-in-Consumer Contract, Warranty and Notice Act.
A Burlington County Superior Court judge denied a motion to dismiss the lawsuit, saying the language in the contract was ambiguous in providing that all complaints had to be settled by a single arbitrator, abiding by rules set by the American Arbitration Association. GWC subsequently appealed.
In reversing, the appellate court judge quoted the language of the service contract: “Under this provision, you waive your right to seek relief in a judicial forum.”
“A plain reading of the arbitration provision demonstrates it is clearly a waiver of the parties' right to pursue claims in court, either on an individual or class-action basis,” the court judge said.
“We are satisfied the terms of the arbitration clause are 'stated with sufficient clarity and consistency to be understood by the consumer who is being charged with waiving [his or] her right to litigate a dispute in court,'” the appeals court said, quoting another Appellate Division panel's 2011 ruling in NAACP of Camden County East v. Foulke Management.
Signor's attorney, Woodbury solo Lewis Adler, declined to comment.
GWC's attorney, Kerri Chewning, of Archer in Haddonefield, didn't return a call seeking comment.
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