## Facts

- Dario Martinez-Gonzalez, a Mexican citizen, worked as a seasonal agricultural laborer in California under the H-2A visa program.
- Elkhorn Packing Co. LLC, a farm labor contractor, and D’Arrigo Bros. Co. of California recruited him in Mexico, sponsored his visa, transported him to California, and provided housing and meals during harvest seasons.
- Martinez-Gonzalez began working in the fields; an orientation occurred a few days later after the workday in the parking lot of worker housing.
- At orientation, workers were instructed to line up and sign a stack of Spanish-language employment documents, including arbitration agreements; supervisors directed where to sign, did not explain the documents, did not provide time to read them, and did not provide copies.
- Martinez-Gonzalez worked three seasons and left during the third; he then sued alleging federal and state wage-and-hour and labor violations.
- Employers moved to compel arbitration based on the signed agreements; the district court denied the motion, finding economic duress and undue influence.

## Issues

1. Whether the arbitration agreements were unenforceable under California law due to economic duress.
2. Whether the arbitration agreements were unenforceable under California law due to undue influence.
3. If enforceable, whether the asserted labor and wage claims fall within the scope of the arbitration agreements.

## Decision

- The Ninth Circuit reversed the order denying arbitration and remanded.
- Economic duress was not established because the employers did not commit a “wrongful act,” and Martinez-Gonzalez had reasonable alternatives.
- Undue influence was not established because the orientation setting and signing process did not show his free will was overcome.
- The case was remanded for the district court to decide, in the first instance, whether the claims are covered by the arbitration agreements.

## Legal Principles

- Under California law, economic duress requires (1) a wrongful act and (2) the absence of a reasonable alternative to consenting.
- Routine employment practices and non-ideal signing circumstances, without unlawful coercion or an improper threat, do not satisfy the “wrongful act” requirement.
- A reasonable alternative may exist where the agreement is not stated or presented as a condition of continued employment, no termination threat is made, and the employee could ask to decline or revoke within an allowed period.
- Under California law, undue influence focuses on whether excessive pressure, considering vulnerability and power imbalance, overcomes the other party’s free will.
- Limited time to read or consult counsel, and instructions to sign quickly, do not alone establish undue influence absent coercion sufficient to overbear the signer’s will.
- On appellate review, a district court’s ultimate conclusions applying these doctrines may be reversed as clearly erroneous when inconsistent with governing state-law standards.

## Conclusion

The Ninth Circuit enforced the employment arbitration agreements, holding that the record did not support economic duress or undue influence under California law, and remanded for a determination whether the plaintiff’s labor and wage claims fall within the agreements’ scope.


Martinez-Gonzalez v. Elkhorn Packing Co. LLC, 25 F.4th 613 (9th Cir. 2022)