California Federal Court Holds That Minors Can Be Bound To Arbitration In A Class Action Context

Duane Morris Takeaways: On December 9, 2025, Judge Yvonne Rogers of the U.S. District Court for the Northern District of California held in Williams, et al. v. Moon Active Ltd., Case No. 4:25-CV-01626 (N.D. Cal. Dec. 9, 2025), that when a minor to a contract states her intent to disaffirm "all contracts" with a defendant, such disaffirmance of a contract "as a whole" presents an issue of contract validity for an arbitrator to resolve, and is not a specific challenge to an arbitration clause's delegation provision that a court must resolve. Under the Williams decision, if a minor wants a court to rule upon the validity of a delegation provision contained within an arbitration agreement, then the minor must specifically disaffirm the delegation provision and not merely the whole of the contract within which the delegation provision appears. As such, this ruling is a required read for corporate counsel managing litigation risks through arbitration program.

Case Background

D.K., a minor, used the defendant's Coin Master mobile game, which allowed users to purchase coins to spin a slot machine feature. When D.K. created an account to play Coin Master, a pop up screen asked her to confirm she was over 18 and that she had read and agreed to Terms and Conditions (Terms) applicable to her usage, with a hyperlink to those Terms also furnished. The opening paragraph of the Terms mentioned in bold that the Terms included an arbitration clause, and provided a link directly to the section of the Terms containing the arbitration clause. The arbitration clause included a delegation provision whereby any disputes concerning the enforceability, validity, scope or severability were delegated to the arbitrator to resolve.

D.K.'s mother filed a class action lawsuit on her behalf asserting claims for negligence, unjust enrichment, and violations of California's unfair competition law, and her counsel then sent letters to the defendant indicating that D.K. disaffirmed "all contracts" with the company. Id. at 3. The defendant moved to compel arbitration.

The Decision

The court granted the motion to compel arbitration. The court first addressed whether an arbitration contract had been formed. Because California law permits a minor to contract in the same manner as an adult subject to the power of disaffirmance, and because conspicuous notice of the arbitration clause was furnished, the court held the Terms were a validly formed contract between the parties.

As to whether D.K. had disaffirmed the Terms by sending a letter to the defendant disaffirming "all contracts," the court agreed with the defendant that such issue was a validity challenge to the Terms as a whole that needed to be resolved by the arbitrator pursuant to the delegation clause. D.K. argued that the delegation clause could not apply since she had disaffirmed the Terms. In rejecting this argument, the court explained that while courts are permitted to decide specific challenges to delegation clauses, it is arbitrators who, pursuant to delegation clauses, are to determine challenges to the validity of an arbitration agreement as a whole. The court found that D.K.'s letter, which disaffirmed "all contracts," was a challenge to the Terms as a whole because the letter did not single out the arbitration clause or its delegation provision. In so holding, the court distinguished the circumstances that were present in J.R. v. Electronic Arts, 98 Cal.App.5th 1107 (2024) because the minor there has specifically disaffirmed "any" contract rather than "all contracts."

Implications of the Decision

The Williams decision highlights the importance of the wording used when a minor seeks to disaffirm an arbitration agreement.

Under Williams, for a court to address the validity of a delegation provision within an arbitration agreement, the minor must specifically disaffirm the delegation provision itself and not generally disavow "all contracts."