Hawaii

Epic Systems Corp. v. Lewis in Hawaii Law

How Epic Systems Corp. v. Lewis applies in Hawaii: state-specific rules, key cases, and bar exam notes for Arbitration.

State Approach

Hawaii follows the federal precedent set by the U.S. Supreme Court in Epic Systems Corp. v. Lewis, reinforcing the enforceability of employee arbitration agreements, including collective action waivers. However, Hawaii courts may scrutinize such agreements more closely for unconscionability and procedural fairness.

State Rule
Arbitration agreements in Hawaii are enforceable as long as they meet the general principles of contract law and are not deemed unconscionable.
Significant State Cases

Hawaii Sys. Corp. v. Summy

The Hawaii Supreme Court reinforced that arbitration agreements would be enforced if they are clear and voluntary.

Aloha Airlines, Inc. v. Tasi

The court held that arbitration clauses should not prevent access to the courts unless clear language is present indicating the intentions of the parties.

Cruz v. DHI Mortgage Co.

The court emphasized the importance of evaluating the fairness of the arbitration process in determining the enforceability of arbitration agreements.

Comparison to Federal Law

Hawaii generally aligns with the federal standard set forth in Epic Systems but maintains a cautious stance towards the potential unconscionability of arbitration clauses. This state-level scrutiny can lead to different outcomes when issues of procedural or substantive fairness are raised compared to certain federal precedents.

Bar Exam Note

Questions on arbitration agreements and unconscionability may appear in the Hawaii bar exam, particularly in the context of employment law.

Practice Pointers
  • Ensure that arbitration clauses are drafted clearly and provide adequate notice to employees.
  • Consider the potential for unconscionability when drafting arbitration agreements.
  • Stay abreast of both federal and state case law regarding arbitration to effectively advise clients.
  • In any arbitration clause, specifically address the waiver of class actions to mitigate future disputes.
  • Evaluate the procedural fairness of the arbitration process to bolster enforceability.

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