Justia Arbitration & Mediation Opinion Summaries

Consolidated appeals arose from of a commercial dispute between Southern Lift Trucks, LLC ("Southern"), and Hyundai Construction Equipment Americas, Inc. ("Hyundai Construction") -- an alleged subsidiary of Hyundai Heavy Industries Co., Ltd. ("Hyundai Heavy Industries"). Southern was a heavy-equipment dealer for Hyundai Construction. Southern filed suit against Hyundai Construction and Hyundai Heavy Industries (collectively, as "Hyundai") asserting various claims, including claims under the Alabama Heavy Equipment Dealer Act ("the AHEDA"). Southern also sought a preliminary injunction to prevent Hyundai: (1) from unlawfully terminating one of the dealer agreements at issue in these appeals; and (2) from unlawfully adding a second dealer in the territory that was covered under another dealer agreement at issue. In response, Hyundai moved to compel arbitration. The circuit court granted Southern's request for a preliminary injunction and denied Hyundai's motion to compel arbitration. In appeal no. SC-2022-0675, the Alabama Supreme Court affirmed the trial court's order insofar as it granted Southern's motion for a preliminary injunction as to the forklift agreement. However, the Court reversed the trial court's order insofar as it issued a preliminary injunction related to the construction-equipment agreement, and remanded the case for the trial court to enter an order consistent with the Supreme Court's opinion. In case no. SC-2022-0676, the Supreme Court affirmed the trial court's order insofar as it denied Hyundai's motion to compel arbitration as to any provisions of Southern's declaratory-judgment claim relating to the "enforceability of any provision" of the dealer agreement. However, the Court reversed the trial court's order insofar as it denied Hyundai's motion to compel arbitration as to Southern's other claims, and that case was remanded for further proceedings. View "Hyundai Construction Equipment Americas, Inc., et al. v. Southern Lift Trucks, LLC" on Justia Law

Alabama Somerby, LLC, d/b/a Brookdale University Park IL/AL/MC; Brookdale Senior Living, Inc.; and Undrea Wright (collectively, Brookdale) appealed a circuit court's order denying their motion to compel arbitration of the claims asserted against them by plaintiff, L.D., as the next friend of her mother, E.D. Brookdale operated an assisted-living facility for seniors ("the nursing home") in Jefferson County, Alabama; Wright was the administrator of the nursing home. In March 2022, L.D. filed on E.D.'s behalf, a complaint against Brookdale and Wright and others, asserting various tort claims and seeking related damages premised on allegations that, following her admission to the nursing home, E.D. had been subjected to multiple sexual assaults both by other residents and by an employee of Brookdale. The Brookdale defendants jointly moved to compel arbitration of L.D.'s claims against them or, alternatively, to dismiss the action without prejudice to allow those claims to proceed via arbitration. Following a hearing, the trial court, denied the motion seeking to dismiss the action or to compel arbitration. The Brookdale defendants timely appealed, asserting that the trial court had erred by failing to order arbitration. The Alabama Supreme Court concluded the Brookdale defendants established that an agreement providing for arbitration existed and that the agreement affected interstate commerce. The trial court erred in denying the Brookdale defendants' request to compel arbitration. The Supreme Court reversed the trial court's order and remanded the case for further proceedings. View "Alabama Somerby, LLC, et al. v. L.D." on Justia Law

The Supreme Court reversed in part the opinion of the court of appeals in this interlocutory appeal concerning whether a subsequent purchaser (Purchaser) of a home is required to arbitrate her claims against the builder (Builder) for alleged construction defects, holding that the trial court erred in granting Purchaser's motion to vacate and denying Builder's motion to confirm.The trial court granted the motion to compel arbitration filed by Builder, which joined two subcontractors in the arbitration, asserting that they owed defense and indemnity obligations. The arbitrator issued an award in favor of Builder. The trial court vacated the award against Purchaser but made no ruling whether to vacate the award against the subcontractors. The Supreme Court rendered judgment confirming the award against Purchaser and remanded the case, holding (1) Purchaser was bound by the arbitration clause in the purchase-and-sale agreement under the doctrine of direct-benefits estoppel; and (2) because the record contained no ruling on whether to vacate the award against the subcontractors, remand was required. View "Lennar Homes of Tex. Land & Construction, Ltd. v. Whiteley" on Justia Law

Plaintiff is a former employee of appellant Cambrian Homecare. When she was hired, Plaintiff signed a written arbitration agreement. Plaintiff brought wage-and-hour claims against Cambrian. Cambrian petitioned for arbitration. The trial court denied the petition. The trial court found that even if the parties had formed an arbitration agreement, the agreement had unconscionable terms, terms that so permeated the agreement they could not be severed.   The Second Appellate District affirmed. The court held that the agreement, read together—as it must be—with other contracts signed as part of Plaintiff’s hiring, contained unconscionable terms. The trial court had discretion to not sever the unconscionable terms and to refuse to enforce the agreement.   The court explained that it has no difficulty concluding that the Arbitration Agreement and the Confidentiality Agreement should be read together. They were executed on the same day. They were both separate aspects of a single primary transaction—Plaintiff’s hiring. They both governed, ultimately, the same issue—how to resolve disputes arising between Plaintiff and Cambrian arising from Alberto’s employment. Failing to read them together artificially segments the parties’ contractual relationship. Treating them separately fails to account for the overall dispute resolution process the parties agreed upon. So, unconscionability in the Confidentiality Agreement can and does affect whether the Arbitration Agreement is also unconscionable. View "Alberto v. Cambrian Homecare" on Justia Law

After being fired by his employer, Anheuser-Busch Companies, LLC, Intervenor filed suit in federal district court, alleging that his termination reflected racial discrimination and retaliation in violation of Title VII. Anheuser-Busch filed a motion seeking to compel arbitration of Intervenor’s district court claims, asserting that at the time when he was hired, Intervenor had agreed to be bound by the company’s Dispute Resolution Policy. Intervenor disagreed that he was required to arbitrate his claims. After Anheuser-Busch asked the district court to compel arbitration, Intervenor filed an unfair labor practice charge with the NLRB, arguing that Defendant’s efforts to enforce its arbitration agreement contravened the collective bargaining agreement and constituted a unilateral change to the terms of Intervenor’s employment, in violation of the National Labor Relations Act (“NLRA”).   The Eleventh Circuit granted the petition for review of the Board’s order dismissing the complaint, vacated the decision of the Board, and remanded for consideration of whether enforcement of the Dispute Resolution Policy against Intervenor would violate the NLRA. The court held that the Board applied an erroneously narrow standard for determining whether Anheuser-Busch’s motion had an illegal objective. The court explained that on remand, the Board should instead determine whether the outcome sought by Anheuser-Busch’s motion— the compelled arbitration of Brown’s Title VII claims under the Dispute Resolution Policy—would violate the NLRA. If the Board decides that the answer to that question is “yes,” it should then order all relief that is appropriate based on Anheuser-Busch’s unlawful conduct. View "International Brotherhood of Teamsters Local 947 v. National Labor Relations Board" on Justia Law

Defendant Niagara Mohawk Power Corporation (the "Company"), which does business as National Grid, is an electric and natural gas utility that operates throughout New York State. According to Plaintiff Local Union 97, International Brotherhood of Electrical Workers, AFL-CIO (the "Union"), Defendant agreed to provide to certain retired employees, former members of the Union. The Union filed a motion to compel arbitration pursuant to section 301(a) of the Labor Management Relations Act, 29 U.S.C. Section 185(a). The same day, the Company filed a motion for summary judgment dismissing the Complaint. The district court granted the Union's motion to compel arbitration, denied the Company's motion for summary judgment, and ordered that the case be closed.   The Second Circuit affirmed, holding that the agreement covers the dispute. The court explained that when it negotiated the Agreement, the Union bargained both for health insurance benefits for retired employees and for a grievance procedure that included, where necessary, access to arbitration. The court explained that it expressed no view on the merits of the Union's grievance; that is a question for the arbitrator. But interpreting the collective bargaining agreement in light of the principles the Supreme Court reaffirmed in Granite Rock, it is clear that the parties intended to arbitrate this dispute. View "Local Union 97, Int'l Bhd. of Elec. Workers, AFL-CIO v. Niagara Mohawk" on Justia Law

The Supreme Court affirmed the judgment of the arbitrator concluding that the Green Bay Police Department had cause to discipline Andrew Weiss for violating several policies of the Green Bay Police Department and demoted him from his position as a detective to a patrol officer, holding that the arbitrator did not exceed his powers.After an investigation, the Department issued a formal complaint alleging that Weiss violated four Department policies. The Department later issued its disciplinary action determining that Weiss violated several policies and demoting him to a position as a patrol officer. After Weiss's grievance was denied he sought arbitration. The arbitrator concluded that the discipline was warranted and did not violate Weiss's due process rights. The Supreme Court affirmed, holding that the arbitrator did not manifestly disregard the law when he determined that Weiss was afforded the process he was due under law. View "Green Bay Professional Police Ass'n v. City of Green Bay" on Justia Law

Plaintiff, an African American woman, worked as a conductor for Amtrak National Railroad Passenger Corporation (Amtrak). During her employment, she belonged to a division of the Sheet Metal, Air, Rail and Transportation Workers (SMART) union, which maintained a collective bargaining agreement (CBA) with Amtrak. Plaintiff brought the instant lawsuit pro se. She named Amtrak and the company’s director of employee relations as Defendants, along with three other Amtrak colleagues. Plaintiff asserted state-law claims of breach of contract and tort, as well as a federal claim of racial discrimination in violation of Title VII. Defendants moved to dismiss, and Plaintiff moved for summary judgment as well as for leave to amend her complaint. The district court granted Defendants’ motion and denied Plaintiff’s two motions. The district court held that Plaintiff’s claims were subject to arbitration under the Railway Labor Act (RLA).   The Fourth Circuit affirmed. The court explained that it declines to unwind a statutory scheme without a clear congressional directive to do so. Plaintiff argued that at least her particular claim is not a minor dispute. The mere fact that Plaintiff’s claim arises under Title VII does not disqualify that claim from being a minor dispute within the RLA’s ambit. The thrust of Plaintiff’s Title VII claim is that Amtrak deviated from its policies when dealing with her. While Plaintiff’s allegations as to her own treatment are factual, those concerning Amtrak’s policies directly implicate the relevant CBA between Plaintiff’s union, SMART, and Amtrak. That some of Plaintiff’s interpretive disagreements concern the Drug-Free Program does not alter the character of her claim. View "Dawn Polk v. Amtrak National Railroad Passenger Corporation" on Justia Law

Current or former Uber drivers from different states agreed to Uber’s “Technology Services Agreement” as a condition of using Uber’s platform. The agreement requires drivers to resolve disputes with Uber on an individual basis through final and binding arbitration. Drivers may opt-out by sending Uber an email or letter. Singh’s class action alleged Uber had violated New Jersey wage and hour laws by misclassifying drivers as independent contractors, failing to pay them the minimum wage, and failing to reimburse them for business expenses. Calabrese’s class action, which was joined to Singh’s, sought to proceed collectively under the Fair Labor Standards Act.The district court ruled in Uber’s favor, compelling arbitration, having defined the relevant class as Uber drivers nationwide. The court found that interstate "rides constitute just 2% of all rides, resemble in character the other 98% of rides, and likely occur due to the happenstance of geography” for purposes of the exception in the Federal Arbitration Act (FAA) for arbitration agreements contained in the “contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce,” 9 U.S.C. 1. The Third Circuit affirmed. The drivers' work is centered on local transportation. Most Uber drivers have never made an interstate trip. When Uber drivers do cross state lines, they do so only incidentally. They are not “engaged in foreign or interstate commerce.” View "Singh v. Uber Technologies, Inc" on Justia Law

The Supreme Court affirmed the opinion of the court of appeals reversing the judgment of the district court refusing to send the underlying rent dispute to arbitration and resolving the claim itself, holding that the dispute should be sent to arbitration.Landlord entered into a lease with Tenant providing that if Tenant defaulted Landlord shall submit such dispute to binding arbitration. When a dispute arose over water damage and withheld rent, litigation and arbitration resulted, with an arbitrator awarding judgment for Tenant. Thereafter, the trustee for several entities that held mortgages on the building brought a foreclosure action against Owner and appointed Receiver. When Tenant continued to refuse to pay rent, Receiver brought suit, and Tenant sought to send the dispute to arbitration. At issue was whether Receiver was bound by the lease's arbitration clause. The district court refused to send the dispute to arbitration and ruled that Tenant must make rent payments to Receiver. The court of appeals reversed. The Supreme Court affirmed, holding that the court of appeals properly concluded that Receiver was subject to the arbitration agreement in the lease. View "Wilmington Trust, Nat'l Ass'n v. 700 Hennepin Holdings, LLC" on Justia Law