May 26, 2026
Court of Appeal, Second Appellate District, Division Eight
The Rule of Watson v. Professional Business Management Corporation is that a nonsignatory defendant cannot compel arbitration based solely on unverified boilerplate allegations in a complaint that it is a "successor, agent and/or alter ego" of a signatory party, under circumstances where the nonsignatory defendant denies the agency relationship and provides no factual evidence to establish its connection to the signatory.
5/5/26
Court of Appeal, First Appellate District, Division Four
The Rule of Robert Toothman v. Redwood Toxicology Laboratory, Inc. is that a nonsignatory employer cannot compel arbitration under a temporary employment agency's arbitration agreement when the employee's claims arise exclusively from direct employment with the nonsignatory employer that occurred after the agency employment ended, under circumstances where the arbitration agreement defines "Company" to include only the agency and its affiliates, subsidiaries and parent companies, and the claims do not arise out of or relate to employment with the temporary agency.