Viking River Cruises, Inc. v. Moriana
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Viking River Cruises, Inc. v. Moriana and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Viking River Cruises, Inc. v. Moriana.
The Supreme Court addressed whether the Federal Arbitration Act (FAA) preempts a California rule that invalidates waivers of representative claims under the Private Attorneys General Act (PAGA). The Court found that the FAA preempts California's rule to the extent it prevents dividing PAGA actions into individual and non-individual claims for arbitration. Consequently, Viking River Cruises was entitled to compel arbitration of Moriana's individual PAGA claim.
Holding
The single most important “bottom line” of what the Court decided in Viking River Cruises, Inc. v. Moriana.
The Court held that the FAA preempts California's rule that prohibits dividing PAGA actions into individual and non-individual claims for arbitration.
Constitutional Concepts
These are the Constitution-related themes that appear in Viking River Cruises, Inc. v. Moriana. Click a concept to see other cases that involve the same idea.
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Why Preemption is relevant to Viking River Cruises, Inc. v. Moriana
The case primarily deals with whether the Federal Arbitration Act preempts California's rule regarding PAGA claims.
Syllabus excerpt (verbatim)The FAA preempts the rule of Iskanian insofar as it precludes division of PAGA actions into individual and non-individual claims through an agreement to arbitrate.
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Why State–Federal Power is relevant to Viking River Cruises, Inc. v. Moriana
The case involves the allocation of authority between state and federal law, specifically regarding arbitration agreements.
Syllabus excerpt (verbatim)Iskanian's prohibition on PAGA waivers is inconsistent with the FAA because PAGA creates an intrinsically representational form of action and Iskanian requires parties either to arbitrate in that format or forgo arbitration altogether.
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Why Standing is relevant to Viking River Cruises, Inc. v. Moriana
The decision discusses the standing of plaintiffs to maintain non-individual PAGA claims once individual claims are arbitrated.
Syllabus excerpt (verbatim)As a result, Moriana would lack statutory standing to maintain her non-individual claims in court, and the correct course was to dismiss her remaining claims.
Key Quotes
Short excerpts from the syllabus in Viking River Cruises, Inc. v. Moriana that support the summary and concepts above.
"The FAA preempts the rule of Iskanian insofar as it precludes division of PAGA actions into individual and non-individual claims through an agreement to arbitrate."
"PAGA provides no mechanism to enable a court to adjudicate non-individual PAGA claims once an individual claim has been committed to a separate proceeding."
"Iskanian's prohibition on PAGA waivers presents parties with an impermissible choice: Either arbitrate disputes using a form of class procedures, or do not arbitrate at all."
