Davidson v. Palantir Technologies, Inc.
3:24-cv-01357
S.D. Cal.Dec 2, 2024Background
- Jeffrey Davidson, a former salesperson for Palantir Technologies Inc., filed suit alleging breach of contract and wage violations after not receiving full commissions for a large sale.
- Davidson was initially hired in Washington and signed an Arbitration Agreement as a condition of employment.
- He later moved to California and signed a Remote Worker Agreement that did not specifically mention arbitration.
- Palantir removed the case to federal court and moved to compel arbitration based on the earlier Arbitration Agreement.
- Davidson opposed, arguing the arbitration provision was superseded by the later agreement and was unconscionable under California law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Remote Worker Agreement superseded the Arbitration Agreement | |||
| Remote Worker Agreement, by not mentioning arbitration, implicitly abrogates the duty to arbitrate | Agreements are not inconsistent; silence does not override explicit arbitration commitment | Remote Worker Agreement does not supersede Arbitration Agreement | |
| Whether the Arbitration Agreement is unconscionable | Agreement is procedurally and substantively unconscionable (adhesion, one-sided, forum selection, choice-of-law) | Agreement is bilateral, not unduly harsh; any unconscionable terms can be severed | Washington law and venue clauses severed; rest is enforceable |
| Enforceability without Defendant’s signature | No signature by Palantir means no agreement | Signature not required if mutual assent is clear | Enforceable without signature |
| Whether claims should go to arbitration | Agreement invalid for reasons above | Valid Arbitration Agreement covers these claims | Claims must be arbitrated; action stayed pending arbitration |
Key Cases Cited
- AT&T Mobility LLC v. Concepcion, 563 U.S. 333 (2011) (FAA reflects broad federal policy favoring arbitration agreements)
- Epic Sys. Corp. v. Lewis, 138 S. Ct. 1612 (2018) (Courts must rigorously enforce arbitration agreements as written)
- Moses H. Cone Mem’l Hosp. v. Mercury Constr. Corp., 460 U.S. 1 (1983) (Any doubts regarding scope of arbitrable issues should be resolved in favor of arbitration)
- Armendariz v. Foundation Health Psychcare Servs., Inc., 24 Cal. 4th 83 (2000) (Defines unconscionability in California law – both procedural and substantive elements required)
- Cione v. Foresters Equity Servs., Inc., 58 Cal. App. 4th 625 (Ct. App. 1997) (Silence on dispute resolution in later agreement does not abrogate earlier arbitration commitment)