Justia Arbitration & Mediation Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals holding that decisions made under Minn. Stat. 43A.33 are quasi-judicial administrative decisions subject to certiorari review by the court but reversed its holding that the Bureau of Mediation Services was a proper party to the appeal, holding that the Bureau was not a proper party to the certiorari appeal.When the Minnesota Department of Corrections sought certiorari review of an arbitrator's decision granting Appellant's appeal from the discharge of his employment at the Minnesota Department of Corrections, Appellant challenged the court of appeals' jurisdiction to hear the appeal, arguing that review must be undertaken by the district court. The court of appeals upheld the arbitrator's decision. The Supreme Court affirmed in part and reversed in part, holding (1) Appellant and the Department were not parties to an arbitration agreement that invoked the judicial review procedures of the Uniform Arbitration Act; (2) the decision of an arbitrator appointed according to section 43A.33 is a quasi-judicial determination of an inferior tribunal reviewable via writ of certiorari at the court of appeals; and (3) the Bureau was not a proper party to this appeal because it had no legal or equitable interest in the outcome. View "Minn. Department of Corrections v. Knutson" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendant-union and denying Plaintiff's motion to vacate an arbitration award, granting Defendant's motion to confirm the award, and awarding attorneys' fees to Defendant as the prevailing party, holding that there was no error.Defendant represented certain municipal employees employed by Plaintiff, West Warwick Housing Authority. After Plaintiff suspended the employment of the grievant, Defendant grieved her termination pursuant to the parties' collective bargaining agreement (CBA). The arbitrator decided in the grievance's favor. Thereafter, Plaintiff filed a complaint seeking to vacate the arbitration award, arguing that the grievance was not substantively arbitrable because the CBA was invalid and that the arbitrator's decision was irrational. The superior court entered judgment in favor of Defendant. The Supreme Court affirmed, holding that the trial justice correctly denied Defendant's motion to vacate because the dispute was arbitrable. View "West Warwick Housing Authority v. R.I. Council 94" on Justia Law

Plaintiff claimed that PeopleConnect used her name and likeness in its Classmates.com school yearbook database without her consent. Plaintiff retained an attorney, who created a Classmates.com account and searched for Plaintiff on the site. In creating the account, the attorney agreed to the Terms of Service, which contained an arbitration provision. Applying Ohio law, the district court denied PeopleConnect’s motion to compel arbitration, holding that there was no evidence that Plaintiff gave her counsel authority to bind her to the Terms of Service containing the arbitration provision.   The Ninth Circuit vacated the district court’s denial of a motion to compel arbitration in an action involving a right of publicity claim against PeopleConnect, LLC under Ohio law. The panel held that the district court erred in applying Ohio law because Washington law governed the threshold question of arbitrability. Here, because no conflict was shown to exist between the law of Washington (the forum state) and Ohio law, Washington law applied. The court held that on the record before the district court, questions of fact precluded ruling on the motion to compel arbitration.   These questions of fact included: whether Plaintiff and her attorney had an agency relationship when her attorney agreed to the Terms of Service; if they did have an agency relationship, whether and how Plaintiff limited her attorney’s authority as her agent; and whether Plaintiff ratified her attorney’s agreement to arbitrate. The court held further that PeopleConnect had a right to conduct discovery on these and related arbitrability issues before the district court decides the motion to compel arbitration. View "BARBARA KNAPKE V. PEOPLECONNECT, INC." on Justia Law

The Supreme Court vacated the judgment of the superior court in favor of Defendant, the Fraternal Order of Police, Lodge 13 (the Union), in which the Court denied the Town of North Providence's petition to vacate an arbitration award and granted the Union's motion to confirm the award, holding that the arbitrator so imperfectly executed his authority that he did not provide a mutual, final, and definite award upon the subject matter, as required under R.I. Gen. Laws 28-9-18(a)(2).This action arose from a dispute between the Union and the Town regarding the effect of a collective bargaining agreement (CBA) governing the employment relationship between the Town and the Town's police officers. The arbitrator found in favor of the Union, and the superior court granted the Union's motion to confirm the award. The Supreme Court reversed, holding that the arbitrator's award failed to draw its essence from the contract, manifestly disregarded relevant portions of the CBA, and produced completely irrational results. View "Town of North Providence v. Fraternal Order of Police, Lodge 13" on Justia Law

The First Circuit reversed the judgment of the district court denying arbitration requested by two unions - the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union and the United Steelworkers Local 12203 (collectively, Union) - on behalf of former two employees of the Boston Gas Company (Company) as to their claims for pension benefits, holding that this matter called for arbitration.The Union represented the two members in filing grievances regarding their underpaid pensions. The Union submitted the grievances to the Joint Pension Committee, which was unable to resolve the dispute. The Union subsequently sought arbitration over the grievances, but the Company refused to arbitrate. The First Circuit reversed, holding that it was up to an arbitrator, not a court, to determine the matters at issue in this case. View "United Steelworkers v. National Grid" on Justia Law

Plaintiff, a citizen and resident of Vietnam, initiated arbitration proceedings in Singapore against Defendant, then a citizen and resident of North Carolina regarding a dispute related to a sale of property in the Philippines. Plaintiff obtained a $1.55 million award against Defendant, and then brought this case asking the court to enforce the award. The district court rejected Defendant's jurisdictional challenges and granted summary judgment in favor of Plaintiff. Defendant appealed.The Fourth Circuit affirmed the district court's order granting summary judgment to Plaintiff. In so holding, the court rejected Defendant's claim that the district court lacked subject matter and personal jurisdiction, and that the court erred in finding no disputed issues of material fact. View "Rachan Reddy v. Rashid Buttar" on Justia Law

The Supreme Court affirmed the order of the district court granting a motion to approve a settlement agreement reached in mediation involving siblings Lily Smith and Sam, Dan, and Vernon Lindemulder, holding that Petitioners were not entitled to relief on their claims of error.The agreement at issue resolved claims involving the Alice M. Lindemulder Trust, established by the parties' mother, which held more than 2,000 acres of land in Stillwater County. Sam appealed the district court's decision to approve the settlement agreement, arguing that the agreement was unenforceable because he lacked the capacity to enter it and had been subjected to undue influence. The Supreme Court affirmed, holding that the district court (1) did not err in concluding that Sam validly consented to the agreement; and (2) did not err in holding that the agreement was valid and enforceable. View "Smith v. Lindemulder" on Justia Law

The Court of Chancery granted Plaintiff's motion for summary judgment seeking an order confirming the arbitration panel's award in this case and denied Defendants' motion for summary judgment seeking to vacate the award, holding that there was no basis to vacate the arbitration panel's award.Defendants initiated arbitration proceedings against Plaintiff to challenge the validity of unsuitability determination that Plaintiff issued to Defendants under the parties' agreement. The arbitration panel determined that the unsuitability determination was valid. This litigation followed. The Court of Chancery confirmed the arbitration award, holding that Defendants were not entitled to relief on their allegations of error. View "MHP Management, LLC v. DTR MHP Management, LLC" on Justia Law

The Supreme Court affirmed the order of the circuit court applying this Court's decision in State ex rel. AMFM, LLC v. King, 740 S.E.2d 66 (W. Va. 2013), to conclude that Respondent lacked authority to bind her mother to an arbitration agreement, holding that there was no error.Respondent admitted her mother to The Villages at Greystone, an assisted living residence, when Respondent was not her mother's attorney-in-fact. In her capacity as her mother's medical surrogate Respondent completed on her mother's behalf a residency agreement and an arbitration agreement. Respondent later sued Petitioners, alleging that her mother had suffered injuries while a resident of Greystone due to Petitioners' negligence. Petitioners filed a motion to arbitrate the claim, but the circuit court denied the motion, concluding that no valid arbitration agreement existed. The Supreme Court affirmed, holding that Petitioners failed to establish a valid agreement to arbitrate on the facts of this case. View "Beckley Health Partners, Ltd. v. Hoover" on Justia Law

California’s Labor Code Private Attorneys General Act (PAGA) authorizes any “aggrieved employee” to initiate an action against a former employer on behalf of himself and other current or former employees to obtain civil penalties that previously could have been recovered only by California’s Labor and Workforce Development Agency. California precedent holds that a PAGA suit is a “representative action” in which the plaintiff sues as an “agent or proxy” of the state. Moriana filed a PAGA action against her former employer, Viking, alleging multiple violations with respect to herself and other employees. Moriana’s employment contract contained a mandatory arbitration agreement with a “Class Action Waiver,” providing that the parties could not bring any class, collective, or representative action under PAGA, and a severability clause. California courts denied Viking’s motion to compel arbitration.The Supreme Court reversed. The Federal Arbitration Act, 9 U.S.C. 1 (FAA), preempts California precedent that precludes division of PAGA actions into individual and non-individual claims through an agreement to arbitrate. Viking was entitled to compel arbitration of Moriana’s individual claim. Moriana would then lack standing to maintain her non-individual claims in court.A PAGA action asserting multiple violations under California’s Labor Code affecting a range of different employees does not constitute “a single claim.” Nothing in the FAA establishes a categorical rule mandating enforcement of waivers of standing to assert claims on behalf of absent principals. PAGA’s built-in mechanism of claim joinder is in conflict with the FAA. State law cannot condition the enforceability of an agreement to arbitrate on the availability of a procedural mechanism that would permit a party to expand the scope of the anticipated arbitration by introducing claims that the parties did not jointly agree to arbitrate. View "Viking River Cruises, Inc. v. Moriana" on Justia Law