Ugalde v. Syngenta Flowers, LLC
5:24-cv-07568
N.D. Cal.Jul 1, 2025Background
- Plaintiff Antonia Verde Ugalde worked as a research lab technician for Syngenta Flowers, LLC, placed via staffing agency ASINC.
- Plaintiff was terminated shortly after providing a doctor's note extending her medical leave following surgery in April 2024.
- Plaintiff filed suit in Santa Clara County Superior Court for disability discrimination and wrongful termination; the case was removed to federal court on diversity grounds.
- Defendants (ASINC and Syngenta) moved to compel arbitration based on an electronically signed arbitration agreement and to stay proceedings.
- Plaintiff opposed, stating she never signed the arbitration agreement and alleging procedural and substantive unconscionability, and waiver of the right to arbitrate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Existence/Authenticity of Arbitration Agreement | Ugalde never saw or signed the agreement; authenticity challenged | Agreement was electronically signed with Ugalde's unique credentials; process authenticated | Defendants established authenticity by preponderance of the evidence |
| Unconscionability | Agreement is procedurally and substantively unconscionable (adhesion, oppression) | Agreement was voluntary, not a mandatory condition, no procedural unconscionability | Plaintiff failed to show procedural unconscionability; agreement enforceable |
| Waiver of Right to Arbitrate | Defendants waived arbitration by their conduct | Defendants timely and clearly sought arbitration | No waiver; Defendants preserved right to arbitrate |
| Stay of Proceedings | No distinct argument | Arbitration agreement covers all claims; stay appropriate | Stay granted pending arbitration |
Key Cases Cited
- Ruiz v. Moss Bros. Auto Grp., 232 Cal. App. 4th 836 (Cal. Ct. App. 2014) (party seeking to compel arbitration bears burden to authenticate agreement)
- Armendariz v. Found. Health Psychcare Servs., Inc., 24 Cal. 4th 83 (Cal. 2000) (procedural and substantive unconscionability both required for unenforceability)
- Mohamed v. Uber Techs., Inc., 848 F.3d 1201 (9th Cir. 2016) (procedural unconscionability is diminished by a voluntary agreement with opt-out)
- Pinnacle Museum Tower Ass’n v. Pinnacle Mkt. Dev. (US), LLC, 55 Cal. 4th 223 (Cal. 2012) (party resisting arbitration bears burden of proving unconscionability)