County of Orange v. U.S. Dist. Court for Cent. Dist. of Cal., No. 14-72343 (9th Cir. 2015)
Annotate this CaseThe County of Orange, California (County) filed a breach of contract action in federal district court against Tata American International Corporation after Tata America did not perform its obligations under the contract to the County’s satisfaction. The complaint included a jury trial demand. Tata America moved to strike the County’s jury demand, arguing that the County waived its right to a jury trial by signing the contract, which contained a jury trial waiver. The district court granted Tata America’s motion to strike, concluding (1) federal law, rather than California law, governed the question of whether the County waived its right to a jury trial in federal court; and (2) the County knowingly and voluntarily waived its right to a jury trial. The Ninth Circuit granted the County’s petition for writ of mandamus, holding (1) the federalism principle announced in Erie R. Co. v. Tompkins requires federal courts sitting in diversity to import state law governing jury trial waivers where, as here, state law is more protective than federal law of the jury trial right; and (2) under California law, the parties’ contractual jury trial waiver was unenforceable, and therefore, the district court erroneously deprived the County of a jury trial when it granted Tata America’s motion to strike.
Court Description: Writ of Mandamus / Erie Doctrine. The panel granted a petition for a writ of mandamus brought by the County of Orange, California, and directed the district court to deny Tata America International Corporation’s motion to strike the County’s demand for a jury trial. Under California law, Grafton Partners, L.P. v. Superior Court, 116 P.3d 479 (Cal. 2005), pre-dispute jury trial waivers are invalid unless expressly authorized by statute. Federal law, on the other hand, permits such waivers as long as each party waived its rights knowingly and voluntarily. The panel held that the five factors to apply to a mandamus petition, and announced in Bauman v. U.S. District Court, 557 F.2d 650 (9th Cir. 1977), did not apply in the extraordinary case where, as here, the petitioner claimed erroneous deprivation of a jury trial. IN RE COUNTY OF ORANGE 3 Because no Federal Rule of Civil Procedure or federal law governs pre-dispute jury trial waivers, the panel applied the “relatively unguided” Erie R. Co. v. Tompkins, 304 U.S. 64 (1938), analysis. The panel found that the law governing pre-dispute jury trial waivers was procedural under Erie, and therefore federal courts should apply federal law to determine the validity of a waiver. The panel also concluded that the federal “knowing and voluntary” standard did not necessarily conflict with California’s Grafton rule because the federal standard was a constitutional minimum courts use to protect litigants’ Seventh Amendment rights to trial by jury. The panel held, therefore, that Erie’s federalism principle required federal courts sitting in diversity to import, as the federal rule, state law governing jury trial waivers, where, as here, state law was even more protective than federal law of the jury trial right. The panel applied California law, and held that the parties’ contractual jury trial waiver was unenforceable. The panel concluded that the district court erroneously deprived a California county of a jury trial when it granted Tata America’s motion to strike, and mandamus relief was therefore warranted.
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