Justia Arbitration & Mediation Opinion Summaries

The Supreme Court reversed the decision of the court of appeals vacating the order of the district court entering judgment on an arbitrator's award, holding that the court of appeals erred in finding the award ambiguous and ordering a remand to the arbitrator for further clarification.Signal 88, LLC brought this contract action against Lyconic, LLC. The district court ordered the dispute to be submitted to arbitration. The arbitrator issued a decision, after which Lyconic applied for an order confirming the arbitration award. The district court confirmed the award but, in the process, modified it. The court of appeals vacated the judgment, determining that the arbitrator's award was ambiguous. The Supreme Court reversed, holding (1) the district court erred in modifying rather than confirming the award; and (2) the court of appeals erred in finding that the arbitrator's award was ambiguous. View "Signal 88, LLC v. Lyconic, LLC" on Justia Law

The Court of Appeal granted the motion to compel arbitration in part and denied in part in a lawsuit alleging tort, contractual and statutory causes of action. The court affirmed the order delaying arbitration until after the court resolves the nonarbitrable causes of action. In the published portion of this opinion, the court concluded that the arbitration agreement carve-out for claims seeking equitable relief is not ambiguous and such causes of action are plainly excluded from the agreement to arbitrate. Therefore, the trial court properly concluded that the six causes of action in plaintiffs' complaint seeking equitable relief fall outside the agreement to arbitrate. View "Eminence Healthcare, Inc. v. Centuri Health Ventures, LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Ahhmigo, LLC's motion to vacate the arbitrator's ruling in favor of The Synergy Company of Utah, LLC in this breach of contract proceeding, holding that the district court did not err.Ahhmigo filed a complaint and demand for arbitration against Synergy, alleging breach of contract, unjust enrichment, and other climes. Synergy agreed to arbitrate Ahhmigo's claims, and the arbitrator ruled in favor of Synergy. Ahhmigo moved the district court to vacate the arbitration award, arguing that the arbitrator had manifestly disregarded the law. The district court denied the motion and confirmed the arbitration award. The Supreme Court affirmed, holding that this Court will not reach the question presented on appeal because Ahhmigo did not raise it in the district court. View "Ahhmigo, LLC v. Synergy Co. of Utah, LLC" on Justia Law

The superior court granted the petition filed by the BH parties to confirm an arbitration award dismissing the investment fraud claims of the Ahern parties as barred by the governing statutes of limitation; denied the Ahern parties' petition to vacate or correct the award; and entered judgment in favor of the BH parties. The arbitration was conducted pursuant to the arbitration provision in the co-tenancy agreement between BH & Sons and tenant in common investors in commercial property.The Court of Appeal reversed and concluded that the trial court erred in compelling arbitration of the Ahern parties' claims under the arbitration provision in the co-tenancy agreement. In this case, the co-tenancy agreement contains a narrow arbitration provision; the investors did not pool funds through the co-tenancy agreement for the purchase of tenant in common interests; the Ahern parties' extracontractual claims are not "rooted in" the co-tenancy agreement; and Civil Code section 1642 does not authorize importing the arbitration provision into the tenant in common purchase and sale agreement. View "Ahern v. Asset Management Consultants, Inc." on Justia Law

The Supreme Court affirmed the judgment of the appellate court remanding this case to the trial court with direction to render judgment in favor of Defendant on Plaintiff's negligence claim that had previously been the subject of mandatory arbitration in a prior civil action, holding that the appellate court's decision was not in error.Plaintiff brought a personal injury action against Defendant in 2015. Before trial, the parties attended arbitration, and the arbitration found in favor of Defendant. The trial court entered judgment in accordance with the arbitrator's decision. Plaintiff then brought the instant action repeating the allegations of negligence in the first action. The trial court granted Defendant's motion to dismiss on the basis of res judicata. The appellate court affirmed on different grounds, concluding that action was not viable because the action had been tried on its merits by the arbitrator and had resulted in a judgment in favor of Defendant. The Supreme Court affirmed, holding that appellate court did not err. View "Larmel v. Metro North Commuter Railroad Co." on Justia Law

PSI filed suit seeking to enjoin an arbitration proceeding filed with FINRA. The district court found that the claimants in the underlying arbitration action were involved in joint business ventures with PSI's former registered representative, not securities transactions governed by FINRA, and thus there was no basis to compel PSI to participate in a FINRA arbitration proceeding.The Eighth Circuit affirmed the district court's grant of injunctive relief enjoining claimants from proceeding with arbitration. The court stated that FINRA's purpose is not to make a brokerage firm the insurer of failed business ventures. In this case, claimants, relying on their own knowledge and expertise, engaged in arms-length business transactions outside of a financial advisor's association with PSI that led purportedly to the loss of millions of dollars. The court concluded that claimants cannot compel arbitration under FINRA Rule 12200 because they have failed to demonstrate that they were the financial advisor's customers—that is, in a relationship with the financial advisor that was related directly to investment or brokerage services. View "Principal Securities, Inc. v. Agarwal" on Justia Law

The First Circuit reversed the judgment of the district court in this dispute between the International Brotherhood of Electrical Workers, Local 103 (the Union) and Johnson Controls Security Solutions, LLC over Johnson Controls' compliance with the terms of the parties' collective bargaining agreement (CBA), holding that the district court erred by failing to order arbitration as called for by a clause in the CBA.Johnson Controls' Norwood, Massachusetts facility entered into a CBA with the Union, a labor organization that represented employees of the company, that contained an arbitration clause. The Union filed a grievance concerning Johnson Controls' reduction in its matching contribution to the company's 401(k) plan, which Johnson Controls denied. When the Union filed a demand for arbitration Johnson Controls brought this lawsuit seeking a declaratory judgment that the dispute was not arbitrable under the CBA. The district court concluded that the dispute was not arbitrable. The First Circuit reversed, holding that nothing in the record showed that the parties intended to exclude this type of dispute from the scope of the arbitration clause. View "Johnson Controls Security Solutions, LLC v. Int'l Brotherhood of Electrical Workers, Local 103" on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court denying the motion to compel arbitration brought by Uber Technologies, Inc. and Rasier, LLC (collectively, Uber) in this action brought by Patricia Sarchi, a user of Uber's ride-sharing service, and the Maine Human Rights Commission, holding that the superior court did not err.Plaintiffs brought this action against Uber for violating the Maine Human Rights Act, Me. Rev. Stat. 5, 4592(8), 4633(2), after Sarchi, who was blind, was refused a ride because of her guide dog. Uber moved to compel Sarchi to arbitrate and to dismiss or stay the action pending arbitration. The motion court denied the motion to compel, concluding that Sarchi did not become bound by the terms and conditions of Uber's user agreement. The Supreme Judicial Court affirmed, holding that, under the facts and circumstances of this case, Sarchi was not bound by the terms. View "Sarchi v. Uber Technologies, Inc." on Justia Law

The Supreme Court held that a deed covenant requiring the arbitration of any dispute arising from a construction defect runs with the land such that it is binding upon a subsequent purchaser of the real estate who was not a party to the deed.The home in this case was constructed and sold by U.S. Home Corp. to the original purchasers. The original deed contained an arbitration provision and several covenants, conditions and restrictions concerning the home that bound both the original purchasers and subsequent purchasers. The original purchasers later sold the home to Plaintiffs, who brought suit against U.S. Home pursuant to Fla. Stat. 553.84. U.S. Home filed a motion to stay and compel arbitration, which the circuit court granted. The Second District Court of Appeal affirmed, concluding that a valid arbitration agreement existed and that it was a covenant running with the land. The Supreme Court approved the decision below, holding that Plaintiffs were bound by the arbitration provision. View "Hayslip v. U.S. Home Corp." on Justia Law

The Second Circuit dismissed plaintiff's appeal of the district court's judgment deeming his Federal Rule of Civil Procedure 41(a)(1)(A)(i) notice of dismissal without prejudice withdrawn and compelling arbitration. The court held that the district court properly retained jurisdiction following the notice of dismissal to conduct a Cheeks review of any possible settlement of plaintiff's Fair Labor Standards Act claims; and that the district court reasonably interpreted his request to continue the litigation as a withdrawal of the notice of dismissal, and, in its discretion, deemed it withdrawn. Therefore, plaintiff failed to take a timely appeal of the order deeming his notice of dismissal withdrawn, and the order to stay and compel arbitration is an unappealable interlocutory order. View "Samake v. Thunder Lube, Inc." on Justia Law