Justia Arbitration & Mediation Opinion Summaries

An 84-year-old man with a history of dementia was admitted to a hospital after several falls and subsequently transferred to a nursing home for rehabilitation. His wife, acting as his “Authorized Representative,” signed an optional arbitration agreement as part of his admission paperwork. During his stay, the man developed a pressure wound that became septic, leading to his removal from the facility and subsequent death. The wife, as personal representative of his estate, filed a wrongful death lawsuit against the nursing home and its administrator, alleging medical negligence and asserting that the man was incompetent and unable to make decisions for himself at the time of admission.The Mobile Circuit Court reviewed the defendants’ motion to compel arbitration, which was based on the signed agreement. The wife opposed the motion, arguing she lacked authority to bind her husband to arbitration because he was permanently incapacitated due to dementia. She provided medical records and her own affidavit to support her claim of his incapacity. The defendants countered with evidence suggesting the man had periods of lucidity and was not permanently incapacitated. The trial court denied the motion to compel arbitration and later denied a postjudgment motion by the defendants that included additional medical records.The Supreme Court of Alabama reviewed the case de novo. It held that the wife did not meet her burden to prove the man was permanently incapacitated or temporarily incapacitated at the time the arbitration agreement was executed. The Court found that the evidence showed the man had lucid intervals and was at times alert and able to communicate, and that no contemporaneous evidence established incapacity at the time of signing. The Supreme Court of Alabama reversed the trial court’s order and remanded the case, holding that the arbitration agreement was enforceable. View "Mobile Nursing and Rehabilitation Center, LLC v. Sliman" on Justia Law

A nursing home resident’s legal representative, acting under a durable power of attorney, sued a nursing home for alleged medical negligence during the resident’s stay. Upon admission, the representative signed several documents, including an agreement to arbitrate any disputes arising from the resident’s care. The representative later claimed not to recall signing the documents but did not dispute her signature. The nursing home moved to compel arbitration based on the signed agreement, which expressly stated it was governed by the Federal Arbitration Act (FAA).The District Court of McCurtain County, Oklahoma, held a hearing on the motion to compel arbitration. The court found that a valid arbitration agreement existed, signed by both an authorized agent of the nursing home and the legal representative. The court determined that the FAA applied due to the involvement of interstate commerce and that the Oklahoma Nursing Home Care Act’s (NHCA) prohibition of arbitration agreements was preempted by federal law. The court granted the nursing home’s motion to compel arbitration and stayed the judicial proceedings.The Supreme Court of the State of Oklahoma reviewed the case de novo. It affirmed the district court’s decision, holding that the FAA preempts the NHCA’s categorical prohibition of arbitration agreements in the nursing home context when interstate commerce is involved and the agreement expressly invokes the FAA. The court found the arbitration agreement was validly executed and not unconscionable, distinguishing this case from prior Oklahoma precedent and aligning with the United States Supreme Court’s decision in Marmet Health Care Center, Inc. v. Brown. The Supreme Court of Oklahoma affirmed the district court’s order compelling arbitration. View "Thompsonl v. Heartway Corp." on Justia Law

Several minors were injured at trampoline parks operated by Sky Zone in Philadelphia. In each instance, only one parent signed a “Participation Agreement, Release and Assumption of the Risk” on behalf of the minor child. The Agreement included a release of liability and an arbitration provision requiring all claims to be resolved by arbitration, waiving the right to a jury trial. After the injuries, lawsuits were filed by both the injured minors’ non-signing parents and the minors themselves, seeking damages for the injuries sustained.The Court of Common Pleas of Philadelphia County reviewed the cases and denied Sky Zone’s petitions to compel arbitration. The trial courts found that the Agreements were enforceable only against the signing parent, not the non-signing parent or the minor child. The courts reasoned that there was no evidence of agency between spouses that would allow one parent to bind the other, and that parents do not have the legal authority to waive a minor’s right to pursue personal injury claims or to bind a minor to an arbitration agreement. The Superior Court of Pennsylvania affirmed these rulings, emphasizing that agency cannot be inferred from marriage alone and that parents, as natural guardians, lack authority over a minor’s property interests, including legal claims, without court approval.The Supreme Court of Pennsylvania reviewed the consolidated appeals. It held that the arbitration agreement signed by one parent is not enforceable against the non-signing parent or the minor child. The Court found that a marital relationship alone does not create an agency relationship, and there was no evidence of express, implied, apparent, or estoppel-based agency. Additionally, the Court held that parents, as natural guardians, lack inherent authority to bind their minor children to arbitration agreements that forfeit the right to a judicial forum and the procedural protections afforded to minors in court. The orders of the Superior Court were affirmed. View "Santiago v. Philly Trampoline Park" on Justia Law

Several minors were injured at trampoline parks operated by Sky Zone in Philadelphia. In each instance, only one parent signed a “Participation Agreement, Release and Assumption of the Risk” on behalf of their child, which included an arbitration provision waiving the right to sue in court. After the injuries, both the signing and non-signing parents, along with the injured minors, brought lawsuits seeking damages for the injuries sustained at the facilities.The Court of Common Pleas of Philadelphia County reviewed petitions by Sky Zone to compel arbitration and stay the litigation, relying on the signed agreements. The trial courts denied these petitions, finding that the agreements were enforceable only against the signing parent. The courts determined that a spouse does not have authority to act as the agent of the other simply by virtue of marriage, and Sky Zone had not provided evidence of agency. Additionally, the courts held that parents do not have the legal authority to waive a minor’s right to pursue personal injury claims or to bind a minor to an arbitration agreement that would require waiving the right to a judicial forum.The Superior Court of Pennsylvania affirmed the trial courts’ decisions, holding that neither the non-signing parents nor the minors were bound by the arbitration provisions. The Superior Court reasoned that agency cannot be inferred from family ties alone and that parents, as natural guardians, lack inherent authority to manage a minor’s property, including legal claims, without court approval.The Supreme Court of Pennsylvania reviewed the case and affirmed the Superior Court’s orders. The Court held that a parent who signs an arbitration agreement cannot bind a non-signing spouse or a minor child to its terms. Specifically, parents lack the authority to bind a minor to an agreement to arbitrate, as this would deprive the minor of judicial protections and oversight designed to safeguard their interests. View "Shultz v. Sky Zone, LLC" on Justia Law

An adolescent female, who was continuously enrolled as a dependent under her mother’s Kaiser health care plans from 2005 to 2023, received gender-affirming medical care between the ages of 13 and 17. After experiencing negative outcomes and later detransitioning, she filed a medical malpractice lawsuit against Kaiser Foundation Hospitals, The Permanente Medical Group, and several individual providers. The claims alleged that the care provided was not medically justified, that risks were not adequately disclosed, and that the providers failed to meet the standard of care in both treatment and informed consent.The Superior Court of San Joaquin County reviewed Kaiser’s petition to compel arbitration, which was based on arbitration provisions in the health plan documents. Kaiser argued that the plaintiff, as a dependent, was bound by arbitration agreements incorporated in the evidence of coverage and benefits booklets for both the union-based and self-funded plans. The trial court found that Kaiser failed to establish the existence of a valid agreement to arbitrate, noting that the relevant documents referenced in the enrollment forms were not provided, and there was no evidence of the plaintiff or her mother expressly agreeing to the specific arbitration provisions Kaiser sought to enforce. The court denied the petition to compel arbitration and later denied Kaiser’s motion for reconsideration.On appeal, the California Court of Appeal, Third Appellate District, affirmed the trial court’s order. The appellate court held that Kaiser did not meet its burden to prove, by a preponderance of the evidence, the existence of a valid and binding arbitration agreement covering the controversy. The court emphasized that mere enrollment and general references to arbitration were insufficient; the precise arbitration provision must be clearly incorporated and agreed to. The order denying the petition to compel arbitration was affirmed. View "Brockman v. Kaiser Foundation Hospitals" on Justia Law

Plaintiffs in this multi-district products liability suit allege that they purchased defective Chrysler Pacifica minivans from FCA, which were recalled due to a risk of battery explosions. After the recall, plaintiffs filed seven putative class action suits, which were consolidated in the Eastern District of Michigan. During discovery, FCA discovered that some plaintiffs had agreed to arbitration clauses when purchasing their minivans and moved to compel arbitration for those plaintiffs. The district court denied FCA’s motion, finding that FCA had waived its right to arbitrate by moving to dismiss the entire complaint.The United States District Court for the Eastern District of Michigan denied FCA’s motion to compel arbitration, concluding that FCA had waived its right to arbitrate by engaging in litigation conduct inconsistent with that right, specifically by moving to dismiss the plaintiffs’ claims. The district court made this finding sua sponte, without the plaintiffs raising the issue of waiver.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court’s decision. The appellate court held that a party cannot waive its right to arbitration without knowledge of that right. The court found that FCA did not know about the arbitration clauses until it obtained the relevant purchase agreements through discovery. Additionally, the appellate court determined that the district court erred by raising the issue of waiver on its own, violating the principle of party presentation. The Sixth Circuit concluded that the district court’s decision was clearly erroneous and remanded the case for further proceedings consistent with its opinion. View "Berzanskis v. FCA US, LLC" on Justia Law

Respondent George Zeber filed a workers' compensation claim for cumulative injury sustained during his employment with the New York Yankees from 1968 to 1978. The Workers’ Compensation Appeals Board (WCAB) found Zeber had a compensable injury but deferred any award pending further proceedings, including mandatory arbitration of the insurance coverage dispute. Travelers Indemnity Company (Travelers) disputed the applicability of mandatory arbitration, arguing it only applies to injuries occurring on or after January 1, 1994, while Zeber's injury occurred no later than 1978.The Workers’ Compensation Judge (WCJ) found Zeber sustained an injury during his employment but deferred findings on permanent disability and other issues. The WCJ also found the statute of limitations did not bar Zeber’s claim, as he only became aware of his right to file a claim in 2017 or 2018. The WCJ determined the New York Yankees had insurance coverage provided by Travelers and noted that disputes involving the right of contribution must be sent to arbitration. Travelers filed for reconsideration, which the WCAB partially granted, amending the WCJ’s decision to defer the insurance coverage issue to mandatory arbitration.The California Court of Appeal, Fourth Appellate District, reviewed the case. The court concluded that section 5275, subdivision (a)(1) applies only to injuries occurring on or after January 1, 1990. The WCJ had not made a finding on the date of injury for purposes of section 5275. The court annulled the WCAB’s decision and remanded the case for further proceedings, including a determination of the date of injury for the purposes of mandatory arbitration. The court emphasized that the "date of injury" for cumulative injuries should be determined under section 5412, which considers when the employee first suffered disability and knew or should have known it was work-related. View "Travelers Indemnity Co. v. Workers' Compensation Appeals Bd." on Justia Law

Cristina Balan, an automotive design engineer, filed a defamation lawsuit against Tesla, Inc. and Elon Musk, alleging that Tesla made defamatory statements about her, including accusations of theft, after an article about her was published in the Huffington Post. Tesla moved to compel arbitration based on an arbitration agreement in Balan's employment contract. The United States District Court for the Western District of Washington partially granted Tesla's motion, compelling arbitration for part of the defamation claim. Balan then amended her arbitration demand to include a defamation claim against Musk.The Western District of Washington initially denied Tesla's motion to compel arbitration in part, but the Ninth Circuit reversed this decision, ruling that the entire defamation claim was subject to arbitration. Consequently, the district court dismissed the case. The arbitrator applied California law and dismissed Balan's defamation claims against Tesla and Musk based on the statute of limitations, issuing an award in favor of Tesla and Musk.Tesla and Musk petitioned the United States District Court for the Northern District of California to confirm the arbitration award. The district court granted the petition, confirming the award. Balan appealed, arguing that the district court lacked subject matter jurisdiction to confirm the award.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the district court lacked subject matter jurisdiction to confirm the arbitration award. The Ninth Circuit cited the Supreme Court's decision in Badgerow v. Walters, which prohibits looking past the face of a petition under 9 U.S.C. § 9 to establish jurisdiction. Since Tesla's petition to confirm a zero-dollar award did not meet the amount in controversy requirement, the Ninth Circuit vacated the district court's order and remanded the case with instructions to dismiss for lack of jurisdiction. View "TESLA MOTORS V. BALAN" on Justia Law

Presley Karlin, a 17-year-old, was injured at Urban Air Springfield, a trampoline and adventure park, due to allegedly inadequate protective cushions. After turning 18, Karlin sued Urban Air for negligence. Urban Air responded by filing a motion to compel arbitration based on an arbitration agreement signed by Karlin’s mother on his behalf. Karlin argued that his mother lacked the authority to sign the agreement and that the agreement only applied to claims arising on the day it was signed, not to his injury four months later.The Circuit Court of Greene County overruled Urban Air’s motion to compel arbitration. Urban Air appealed, limiting its arguments to the arbitration agreement signed by Karlin’s mother. The court reviewed the case de novo, focusing on whether the arbitration agreement contained a delegation clause that required threshold issues of arbitrability to be decided by an arbitrator.The Supreme Court of Missouri found that the arbitration agreement did contain a delegation clause, which required any disputes about the scope, arbitrability, or validity of the agreement to be settled by arbitration. Since Karlin did not specifically challenge the delegation clause itself, the court held that the clause was valid and enforceable. Consequently, Karlin’s claims regarding the validity and scope of the arbitration agreement must be presented to the arbitrator.The Supreme Court of Missouri vacated the circuit court’s order and remanded the case with instructions to sustain Urban Air’s motion to compel arbitration. View "Karlin vs. UATP Springfield, LLC" on Justia Law

Trudy Maxwell, a 93-year-old resident of Atria Park of San Mateo, died after consuming an industrial strength cleaner mistakenly served as a beverage by an Atria employee. Trudy’s eight children, including James Maxwell III, filed a lawsuit against Atria Management Company and related entities, alleging negligence, wrongful death, and elder abuse. James III, holding a durable power of attorney (DPOA), had signed an arbitration agreement with Atria, which the defendants sought to enforce.The San Mateo County Superior Court denied the defendants' motion to compel arbitration, ruling that James III was not authorized to sign the arbitration agreement because he did not have the authority to make health care decisions for Trudy. The court also found that the arbitration agreement did not bind Trudy’s children regarding their wrongful death claims and that California procedural rules, including section 1281.2(c), were not preempted by the Federal Arbitration Act (FAA).The California Court of Appeal, First Appellate District, Division One, reviewed the case. The court reversed the trial court’s order denying arbitration and remanded the case for further proceedings. The appellate court instructed the trial court to reconsider the validity of the arbitration agreement in light of the California Supreme Court’s decision in Harrod v. Country Oaks Partners, LLC, which held that agreeing to an optional arbitration agreement is not a health care decision. The appellate court also affirmed that the wrongful death claims of Trudy’s children are not subject to arbitration, as they are independent and personal claims not bound by the arbitration agreement. The court further held that section 1281.2(c) was not preempted by the FAA, allowing the trial court to stay or deny arbitration to avoid conflicting rulings. View "Maxwell v. Atria Management Co., LLC" on Justia Law