Justia Arbitration & Mediation Opinion Summaries

JES Farms Partnership sold crops through Indigo Ag's digital platform. In 2021, JES initiated arbitration against Indigo, alleging breach of a marketplace seller agreement and trade rule violations. Indigo counterclaimed, alleging JES breached the agreement and its addenda. JES then sought a federal court's declaratory judgment that Indigo’s counterclaims were not arbitrable and that some addenda were invalid. Indigo moved to compel arbitration based on the agreement's arbitration clause.The United States District Court for the District of South Dakota partially denied Indigo's motion. The court agreed that Indigo’s counterclaims were arbitrable but ruled that the enforceability of the addenda was not arbitrable under the marketplace seller agreement. The court found the arbitration clause "narrow" and concluded that disputes about the addenda's enforceability did not relate to crop transactions. Indigo appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court determined that the arbitration clause in the marketplace seller agreement was broad, covering "any dispute" related to the agreement or transactions under it. The court found that the enforceability of the addenda was indeed a dispute "relating to crop transactions" and thus fell within the scope of the arbitration clause. Consequently, the Eighth Circuit reversed the district court's decision and directed it to grant Indigo’s motion to compel arbitration and address the case's status pending arbitration. View "JES Farms Partnership v. Indigo Ag Inc." on Justia Law

Bachman Farms grows apples in Ohio and protected its 2017 crop with federally reinsured crop insurance from Producers Agriculture. When farmers and private insurers enter a federally reinsured crop insurance contract, they agree to common terms set by the Federal Crop Insurance Corporation (FCIC), including a requirement that the parties arbitrate coverage disputes. In those proceedings, the arbitrator must defer to agency interpretations of the common policy. Failure to do so results in the nullification of the arbitration award. Bachman lost at its arbitration with Producers Agriculture and alleged that the arbitrator engaged in impermissible policy interpretation. Bachman petitioned to nullify the arbitration award.The Sixth Circuit affirmed the dismissal of the suit. The petition to nullify did not comply with the substance or the three-month time limit of the Federal Arbitration Act (FAA), 9 U.S.C. 12. When a dispute concerning federally reinsured crop insurance involves a policy or procedure interpretation, the parties “must obtain an interpretation from FCIC.” Bachman did not seek an interpretation from FCIC but went directly to federal court to seek nullification under the common policy and its accompanying regulations—an administrative remedy—rather than vacatur under the FAA. View "Bachman Sunny Hill Fruit Farms v. Producers Agriculture Insurance Co." on Justia Law

Elkhorn is a farm labor contractor for a California-based vegetable grower. As part of Elkhorn’s orientation for incoming employees, Martinez-Gonzalez signed employment paperwork that included arbitration agreements. The district court held that the arbitration agreements resulted from undue influence and economic duress and were invalid and unenforceable.The Ninth Circuit reversed and remanded for determination of whether Martinez-Gonzalez’s allegation of federal and state labor and wage law violations fell within the scope of the arbitration agreements. Under California law, the doctrine of economic duress did not render the arbitration agreements unenforceable because Elkhorn did not commit a wrongful act and reasonable alternatives were available to Martinez-Gonzalez. Martinez-Gonzalez made the journey from Mexico to California, where he was dependent on Elkhorn housing and had already started work but, while “not ideal,” those circumstances did not constitute a “wrongful act” under California law. No one at Elkhorn told Martinez-Gonzalez that refusing to sign the agreements was a cause for termination. It was clearly erroneous for the district court to conclude that MartinezGonzalez lacked a reasonable alternative. The timing and place of the orientation did not show that Martinez-Gonzalez’s will was overborne; the lack of time to consult with attorneys or read the agreements did not improperly induce his signatures. Elkhorn’s representatives’ instructions to sign the agreements quickly were not insistent demands. View "Martinez-Gonzalez v. Elkhorn Packing Co. LLC" on Justia Law