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 the rule insofar as it prevents the division of PAGA actions into individual and non-individual claims through arbitration agreements. The decision allows arbitration of individual PAGA claims while dismissing non-individual claims due to lack of standing.
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 the California 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 a California rule.
Syllabus excerpt (verbatim)The question for decision is whether the Federal Arbitration Act... preempts a rule of California law...
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Why Standing is relevant to Viking River Cruises, Inc. v. Moriana
The Court discusses the standing requirements under PAGA and how they are affected by arbitration agreements.
Syllabus excerpt (verbatim)And under PAGA's standing requirement, a plaintiff has standing to maintain non-individual PAGA claims in an action only by virtue of also maintaining an individual claim in that action.
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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 law (California's PAGA) and federal law (FAA).
Syllabus excerpt (verbatim)Viking was entitled to compel arbitration of Moriana's individual claim... Iskanian's rule that PAGA actions cannot be divided into individual and non-individual claims is preempted.
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's built-in mechanism of claim joinder is in conflict with the FAA.
Moriana would lack statutory standing to maintain her non-individual claims in court.