Douglass v. Serenivision, Inc.

*380There is a "strong presumption that courts should determine the jurisdiction of arbitrators." ( Sandquist v. Lebo Automotive, Inc. (2016) 1 Cal.5th 233, 249, 205 Cal.Rptr.3d 359, 376 P.3d 506 ( Sandquist ).) Parties may nevertheless agree to let an arbitrator decide his or her own jurisdiction, at least if their agreement to do so is " 'clear [ ] and unmistakabl[e].' " ( Howsam v. Dean Witter Reynolds, Inc. (2002) 537 U.S. 79, 83, 123 S.Ct. 588, 154 L.Ed.2d 491 ( Howsam ).) Does a party clearly and unmistakably consent to have an arbitrator decide his own jurisdiction when that party does not…