Does the third-party litigation exception apply?

Williams v. Atria Las Posas, 24 Cal. App. 5th 1048, 1057-58 (2018)). The appellate court held that the trial court erred by not analyzing the three factors to determine whether the third-party litigation exception applies. See id. at 1055. The exception applies when the following conditions are satisfied: (1) a party to the arbitration agreement is also a party to a pending court action with a third party; (2) the third-party action arises out of the same transaction or series of transactions; and (3) there is a possibility of conflicting rulings on a common issue of law or fact. See id. at 1054.