Young

FACTS

Plaintiff is a prior employee of defendant who worked as a warehouse shipping, receiving, and delivery driver in defendant’s customer- facing store located in Modesto, California. In January 2022, as part of an onboarding process, defendant presented plaintiff with a “Mutual Binding Arbitration Agreement” (agreement), accompanied by a written communication from defendant’s director of human resources. The latter provided notice that defendant “ha[d] adopted an alternative dispute resolution program to resolve complaints that an employee has with [defendant] and/or [defendant] has with an employee.” It further explained “[a]rbitration is a process for resolving disputes outside of the court system,”

2 and stated the agreement would “allow each party to submit their own claims, which might otherwise have been brought in the court system, for resolution by the arbitrator.” And in closing, the communication “encourage[d] all employees to review the attached [agreement],” as well as conveyed that “[a]ll employees are required to agree to and be bound by the . . . [a]greement.” The four-page agreement generally provides for mandatory binding arbitration under the Federal…