The U.S. Court of Appeals for the Ninth Circuit affirmed a lower court's decision denying a motion to compel arbitration in *Gonzales v. Rose Hills Company*, a class action employment lawsuit that could have significant implications for workers in the funeral services industry.
Manuel Gonzales filed the lawsuit on behalf of himself and similarly situated workers against Rose Hills Company, a Delaware corporation that operates one of the nation's largest cemeteries. The case also names Service Corporation International, SCI Shared Services, Inc., and Dignity Memorial as defendants. Service Corporation International is among the largest funeral service providers in North America.
The dispute centered on the defendants' attempt to force the case into private arbitration rather than allowing it to proceed as a public class action lawsuit. The employers argued that Gonzales and other workers were bound by arbitration agreements that required individual dispute resolution rather than collective legal action.
U.S. District Judge Maame Ewusi-Mensah Frimpong of the Central District of California initially denied the defendants' motion to compel arbitration, finding that the companies failed to establish the existence of valid arbitration agreements with the workers. The defendants appealed this decision to the Ninth Circuit.
In a memorandum opinion filed Feb. 5, 2026, a three-judge panel consisting of Circuit Judges Callahan, Owens, and Koh unanimously affirmed the district court's ruling. The appeals court applied a de novo standard of review for the legal question of whether to compel arbitration, while reviewing any underlying factual findings for clear error.
The Ninth Circuit noted that it had jurisdiction to review the arbitration dispute under 9 U.S.C. § 16, which allows immediate appeals of orders denying motions to compel arbitration. This statutory provision recognizes the importance of resolving arbitration questions quickly, as the Federal Arbitration Act generally favors enforcement of valid arbitration agreements.
The court's decision cited *Berman v. Freedom Financial Network, LLC*, a 2022 Ninth Circuit precedent that established the review standards for arbitration disputes. Under this framework, appellate courts examine de novo whether parties agreed to arbitrate their disputes, while giving deference to trial courts' factual determinations about the circumstances surrounding any alleged agreements.
While the court's memorandum opinion does not detail the specific employment claims at issue, class action lawsuits against funeral service companies often involve allegations of wage and hour violations, including unpaid overtime, missed meal and rest breaks, and improper classification of workers. Such cases can affect hundreds or thousands of employees across multiple locations.
The defendants' failure to establish arbitration agreements means that Gonzales and the proposed class of workers can continue pursuing their claims in federal court rather than being forced into individual arbitration proceedings. This distinction is significant because class actions allow workers to pool resources and leverage collective bargaining power against large corporations, while arbitration typically involves private, individual proceedings with limited discovery and no right to appeal.
Rose Hills Company operates Rose Hills Memorial Park in Whittier, California, which spans more than 1,400 acres and serves as one of the largest cemeteries in the world. The company is part of a network of funeral service providers that includes Service Corporation International, which operates more than 1,500 funeral homes and 400 cemeteries across North America.
The appellate court's decision represents a victory for workers' rights advocates who argue that mandatory arbitration clauses can prevent employees from effectively challenging workplace violations. Critics of forced arbitration contend that these agreements often favor employers and limit workers' ability to seek meaningful relief for violations of labor laws.
The case now returns to the Central District of California, where Judge Frimpong will continue overseeing the litigation. The defendants may still challenge class certification and contest the underlying employment claims on their merits, but they will not be able to force the dispute into private arbitration.
The Ninth Circuit's ruling could influence similar employment disputes throughout the western United States, where the court's jurisdiction extends across nine states and two territories. While the decision is designated as a memorandum opinion that is not appropriate for publication and does not create binding precedent, it provides guidance for how courts should analyze arbitration agreements in employment class actions.
The case highlights ongoing tensions between employers' preferences for private dispute resolution and workers' rights to pursue collective legal action. As more companies incorporate arbitration clauses into employment agreements, courts must carefully examine whether these provisions were properly formed and apply to the specific disputes at hand.