
In a published decision that strengthens protections for California workers, the Court of Appeal ruled in De León v. Pinnacle Property Management Services, LLC (111 Cal. App. 5th 1009, 2025) that a procedurally and substantively unconscionable arbitration agreement cannot be enforced—even if it appears clearly worded and signed during onboarding.
The decision represents a major victory for Employees First Labor Law (EFLL), whose attorneys Jonathan LaCour and Lisa Noveck successfully argued that the agreement violated basic principles of fairness and due process. The ruling is expected to have broad application across California, especially for low-wage and non-exempt workers pressured into signing one-sided arbitration agreements as a condition of employment.
Case Background

Plaintiff: Anthony De León
Defendant: Pinnacle Property Management Services, LLC
Representation: Jonathan LaCour & Lisa Noveck, Employees First Labor Law
Court: California Court of Appeal, Fourth Appellate District
Decision: Arbitration agreement unenforceable due to unconscionability
De León, a non-exempt employee, was required to sign an “Issue Resolution Agreement” electronically during his onboarding process. The agreement included:
- A mandatory arbitration clause
- A one-year statute of limitations
- Severe limitations on discovery
When De León later brought legal claims, Pinnacle moved to compel arbitration. The trial court denied that motion, and on appeal, EFLL attorneys successfully defended that ruling. The Court affirmed in full.
Why the Court Struck Down the Arbitration Agreement
1. Procedural Unconscionability: Coercion & Lack of Choice
- The arbitration agreement was presented on a take-it-or-leave-it basis as part of electronic onboarding.
- De León had no opportunity to negotiate and was not advised he could consult legal counsel.
- The Court emphasized that the power imbalance and rushed execution supported a finding of coercion.
“The adhesive nature of the agreement, combined with time pressure and lack of explanation, rendered the agreement procedurally unconscionable.”
2. Substantive Unconscionability: Unfair and One-Sided Terms
The Court also found that key terms of the agreement were unreasonably harsh:
- One-year limitations period: Cut off claims that normally enjoy longer filing periods under California law.
- Discovery restrictions: Severely limited the number of interrogatories and depositions, undermining De León’s ability to prove statutory violations.
3. No Severance – The Whole Agreement Was Tainted
Rather than try to sever the unfair provisions, the Court held the entire agreement was “permeated with unconscionability.”
EFLL’s Role in Shaping the Law
This was not just a case win—it’s a published appellate decision that will serve as binding precedent for:
- Trial courts across California reviewing arbitration clauses
- Plaintiffs’ attorneys evaluating whether to challenge arbitration
- Employers seeking to enforce agreements signed under questionable conditions
Jonathan LaCour and Lisa Noveck of EFLL successfully preserved worker rights and established new legal standards that benefit all Californians—not just their client.
Broader Implications
| Legal Principle | De León’s Contribution |
|---|---|
| Adhesion contracts scrutiny | Even “stand-alone” arbitration agreements are suspect if signed under pressure |
| Limitations periods | Agreements cannot shorten legally protected timelines for filing employment claims |
| Discovery rights in arbitration | Overly restrictive discovery provisions will invalidate agreements |
| Employer burden of fairness | Burden is on employers to design and implement fair, voluntary arbitration terms |
Key Takeaways for Workers
You may have signed an arbitration agreement—but that doesn’t always mean you’re stuck with it. If:
- You signed on your first day with no explanation or time to review;
- You weren’t told you could talk to a lawyer;
- The agreement limits your time to file or restricts your ability to get evidence…
Then you may be able to fight arbitration—and win.
EFLL: Defending Workers, Changing the Law
This landmark victory in De León v. Pinnacle is part of Employees First Labor Law’s mission: to not only defend individual workers—but to reshape the legal landscape in favor of fairness and accountability.
If you’ve been forced to sign an unfair arbitration agreement, let our appellate-proven team help you fight back.
We’re Ready to Help



