West Coast Dental Administrative Services, LLC, a Delaware corporation, manages a network of dental facilities throughout California. The company provides administrative and support services to affiliated dental practices and professional corporations via support services agreements. It sources materials from outside California and, at the time relevant to this case, maintained offices and employees in both California and Washington until January 2022, with differences in employee benefits outlined in its handbook.
West Coast Dental hired Sinedou S. Tuufuli as a collector and customer service representative. Tuufuli electronically signed an arbitration agreement that stipulated that any disputes related to her employment or termination would be resolved through final and binding arbitration. It explicitly stated that the agreement “shall be governed by the Federal Arbitration Act and, to the extent permitted by such Act, the laws of the State of California.”
In April 2023, Tuufuli filed a lawsuit against West Coast Dental, asserting eight individual and class claims for violations of various provisions of the California Labor Code and Business and Professions Code. These claims alleged labor-related issues, such as unfair compensation and working conditions, on behalf of herself and a class of similarly situated employees.
West Coast Dental filed a motion to compel arbitration of Tuufuli’s individual claims and to dismiss her class claims. In support, the company’s human resources manager submitted a declaration affirming its Delaware incorporation, former offices in Washington, and sourcing of out-of-state materials. West Coast Dental also provided a copy of the employee handbook given to Tuufuli, which detailed interstate operations and benefits differences. Tuufuli opposed the motion, arguing that the Federal Arbitration Act (FAA) did not apply because there was no evidence of interstate commerce involvement or contemplation thereof, and that West Coast Dental operated exclusively in California. Tuufuli worked exclusively in California and testified that she rarely interacted with individuals or entities outside the state in performing her duties.
The trial court granted West Coast Dental’s motion. It determined that the FAA governed the agreement, relying on the evidence of West Coast Dental’s interstate activities (e.g., Delaware incorporation, Washington offices, and out-of-state sourcing) as well as the explicit provision in the agreement stating it was governed by the FAA. Finally, the court dismissed Tuufuli’s class claims, citing the agreement’s express prohibition on class arbitration or litigation.
Tuufuli appealed, challenging only the trial court’s finding that the FAA applied to the arbitration agreement. She did not contest the agreement’s validity or the dismissal of class claims on other grounds.
The Court of Appeal affirmed the trial court’s order compelling arbitration of Tuufuli’s individual claims and dismissing her class claims in the published case of Tuufuli v West Coast Dental Administrative Services, LLC -B338584.PDF (January 2026).
The appellate court agreed with the trial court that the FAA applied, but primarily because the parties had explicitly agreed to it in the arbitration agreement’s governing law provision. It rejected Tuufuli’s argument that parties cannot contractually invoke the FAA without proving interstate commerce involvement, emphasizing that arbitration under the FAA is a matter of consent, not coercion, and parties are generally free to structure their agreements as they see fit (citing Volt Information Sciences, Inc. v. Board of Trustees of Leland Stanford Junior University (1989) 489 U.S. 468, 479).
The court distinguished the U.S. Supreme Court’s decision in Allied-Bruce Terminix Cos. v. Dobson (1995) 513 U.S. 265, which held that the FAA applies to contracts that in fact involve interstate commerce, even if not contemplated by the parties. The appellate court clarified that Allied-Bruce did not prohibit parties from voluntarily electing FAA governance; it merely addressed the scope of “involving commerce” under 9 U.S.C. § 2. Similarly, the court rejected Tuufuli’s analogy to 9 U.S.C. § 1, which expressly exempts transportation workers’ contracts from the FAA regardless of agreement. Section 2, by contrast, contains no such exemption for non-interstate contracts and simply enforces arbitration provisions in contracts involving commerce (or, by extension, where parties consent to FAA application).
Given this consent-based reasoning, the appellate court declined to address whether the agreement independently involved interstate commerce based on West Coast Dental’s operations.