In August 2017, Sinedou Tuufuli worked as a collector and customer service representative for West Coast Dental, an entity that manages the business operations of affiliated dental practices and provides those practices support and administrative services.
When Tuufuli was hired, she electronically signed an arbitration agreement, which required any disputes with West Coast Dental relating to her employment must be resolved by final and binding arbitration. The arbitration agreement stated that the parties agreed to arbitrate claims based on any federal, state, or local law, including the California Fair Employment and Housing Act (FEHA), the California Labor Code, the California Unfair Competition Law, and the California Wage Orders. It further stated that the arbitrator would not have the authority to preside over class, collective, or other representative proceedings. The arbitration agreement said it would be governed by the Federal Arbitration Act (FAA) and, “to the extent permitted by such Act, the laws of the State of California.”
In April 2023, Tuufuli filed a complaint against West Coast Dental, asserting eight individual and class claims for violations of the Labor Code and the Business and Professions Code. West Coast Dental moved to compel arbitration and dismiss her class claims. It also argued that the arbitration agreement was governed by the FAA.
In March 2024, the trial court granted West Coast Dental’s motion to compel arbitration and dismissed Tuufuli’s class claims. The trial court relied on the evidence West Coast Dental supplied showing it operated in multiple states and on provisions within the arbitration agreement that said it was governed by the FAA. The trial court dismissed the class claims because the arbitration agreement prohibited Tuufuli from litigating or arbitrating class claims against West Coast Dental. Tuufuli appealed.
The Court of Appeal explained that the FAA reflects a liberal federal policy favoring arbitration agreements. The FAA preempts state laws that “require a judicial forum to resolve claims which the contracting parties agreed to resolve by arbitration.” The FAA applies if the parties expressly agreed that it will. Arbitration under the FAA is a matter of consent and parties may voluntarily elect to have the FAA govern enforcement of their arbitration agreement.
The Court of Appeal agreed with the trial court that the FAA governed the arbitration agreement between Tuufuli and West Coast Dental because they expressly agreed that it would. The Court of Appeal therefore affirmed the order compelling arbitration and dismissing the class claims.
Tuufuli v. West Coast Dental Administrative Services, LLC (Jan. 13, 2026, No. B338584) ___Cal.App.5th___ .
Note: This decision reinforces that arbitration agreements used by private schools may be governed by the Federal Arbitration Act based on the parties’ express agreement. Private school employers that wish to invoke FAA governance should ensure their arbitration agreements clearly state that the FAA applies.