Justia Alabama Supreme Court Opinion Summaries

Several former employees of Alabama Psychiatric Services, P.C. ("APS"), filed a putative class action against APS and Managed Health Care Administration, Inc. ("MHCA"), an affiliate of APS, alleging APS had not paid the former employees for unused vacation time after they lost their jobs when APS went out of business. APS and MHCA moved the circuit court to compel arbitration pursuant to arbitration agreements the plaintiffs had entered into with APS. APS and MHCA asked the circuit court to determine, as a threshold question, whether class arbitration was available in this case because the arbitration agreements at issue did not expressly mention class arbitration. The circuit court issued an order granting the motion to compel arbitration, declining to decide whether class arbitration was available, concluding that that issue was to be decided by the arbitrator. The case proceeded to arbitration. The arbitrator issued a clause-construction award ("the award"), concluding that the relevant arbitration agreements authorized class arbitration in this case. APS and MHCA sought review of the award by the circuit court, which denied the motion to vacate the arbitrator’s award. The parties then applied to the Alabama Supreme Court, which noted multiple procedural irregularities in the circuit court’s order. The issue of whether the circuit court erred regarding its order not vacating the arbitration agreement was not properly before the Supreme Court. APS and MHCA attempted to challenge that part of the order compelling arbitration in which the circuit court declined to decide the availability of class arbitration. However, to properly challenge that aspect of the earlier order, APS and MHCA should have appealed the order. APS and MHCA also argued the circuit court erred by failing to apply a de novo standard of review of the arbitrator’s award. The Supreme Court determined the circuit court did not err in this respect. The Supreme Court therefore affirmed the circuit court in denying the motion to vacate the arbitrator’s award, and dismissed appeal 1171150 as redundant. View "Alabama Psychiatric Services, P.C. v. Lazenby et al." on Justia Law

Greenway Health, LLC, and Greenway EHS, Inc. (formerly EHS, Inc.) (collectively, "the Greenway defendants"), and Sunrise Technology Consultants, LLC, and Lee Investment Consultants, LLC (collectively, "the Sunrise defendants"), appealed separately a circuit court order denying their motion to compel the arbitration of certain claims asserted against them by Southeast Alabama Rural Health Associates ("SARHA"). Because the Alabama Supreme Court determined the Greenway defendants failed to establish the existence of a contract containing an arbitration provision, the Sunrise defendants' argument based on an intertwining-claims theory also failed. The Court therefore affirmed the trial court's denial of the Greenway defendants' and the Sunrise defendants' motions to stay proceedings and to compel arbitration. View "Greenway Health, LLC, and Greenway EHS, Inc. v. Southeast Alabama Rural Health Associates" on Justia Law

William Carroll, M.D., Loring Rue, M.D., and Gustavo Heudebert, M.D. (collectively, defendants), appealed a circuit court's denial of their motion to compel arbitration of claims asserted against them by Paul F. Castellanos, M.D. Dr. Castellanos alleged that he was an "internationally recognized" physician with a specialty practice as a "laryngologist and bronchoesophagologist (airway surgeon)" who was "recruited to come to the University of Alabama at Birmingham in 2005 to establish a center of excellence for the treatment of voice and aero digestive disorders at University of Alabama, Birmingham Academic and Medical Center" ("UAB Medical Center"). University of Alabama Health Services Foundation, P.C. ("UAHSF") and Dr. Castellanos executed a "Physician Employment Contract" describing the details of his employment, which contained an arbitration provision. The questions whether the individual defendants, as nonsignatories to the employment contract, could enforce the arbitration provision in that contract and whether the arbitration provision encompassed Dr. Castellanos's claims against the individual defendants were questions for the arbitrator, not the court, pursuant to the arbitration provision in the employment contract. The Alabama Supreme Court determined the circuit court erred in denying the individual defendants' motion to compel arbitration. The Court therefore reversed the order and remanded the case for further proceedings. View "Carroll v. Castellanos" on Justia Law

The issue this case presented for the Alabama Supreme Court’s review was who had the power to determine the location of an arbitration proceeding: an arbitrator or Circuit Court. The Court concluded that, under the facts of this case, the arbitrator had that power; thus, reversed and remanded. View "Alliance Investment Company, LLC v. Omni Construction Company, Inc., a/k/a OCC, Inc" on Justia Law

In 2014, Jeremy Gowan filed this action against Cavalier Home Builders, LLC, d/b/a Buccaneer Homes ("Buccaneer"), Minton Industries, Inc. ("Minton"), Monster Movers, LLC ("Monster Movers"), Jerry Dudley, and Britt Richards. Buccaneer, Dudley, Richards, and Minton moved to compel arbitration based on an arbitration agreement Gowan had signed relating to the sale of a manufactured home. Although Monster Movers was not a party to the arbitration agreement, Gowan's claims against Monster Movers were submitted to arbitration by consent of the parties. While the arbitration proceeding was pending, Monster Movers entered into a joint dismissal with Gowan. The case proceeded to arbitration against the remaining defendants. In 2017, the arbitrator issued an award in favor of Gowan and against Buccaneer in the amount of $10,000. As to Gowan's claims against all other remaining defendants, the award was adverse to Gowan. Gowan appealed the award to the circuit court on the basis that the award was insufficient against Buccaneer. The Alabama Supreme Court determined the circuit court deviated from the procedure for the appeal of an arbitration award established by Rule 71B, Ala. R. Civ. P. The issue raised in the mandamus petition was made moot, and the Supreme Court declined further review. View "Ex parte Cavalier Home Builders, LLC, d/b/a Buccaneer Homes." on Justia Law

Rhonda Stephan as the personal representative of the Estate of Bobby Gene Hicks, appealed an order granting a motion to compel arbitration filed by Millennium Nursing and Rehab Center, Inc. Stephan contends that Hicks, her father, died in 2015 while he was a resident at Millennium Nursing and Rehabilitation Center, a skilled-nursing facility owned and operated by Millennium ("the Rehab Center"). During Hicks's hospitalization at Crestwood Medical Center ("Crestwood"), Stephan signed all the paperwork arranging for her father to be discharged from the hospital and transferred to the Rehab Center; however, she did not hold a power of attorney or other actual legal authority to act on Hicks's behalf or to contract in his name. Hicks did not sign any of the paperwork, but he is named as a party to the contracts included within that paperwork. On October 26, 2015, Hicks was transferred from Crestwood to the Rehab Center. The Alabama Supreme Court concluded Stephan could not be bound to the arbitration provision in her capacity as personal representative to Hicks' estate when she signed the agreement at issue here in her capacity, in what amounted to, Hicks' relative or next friend. View "Stephan v. Millennium Nursing and Rehab Center, Inc." on Justia Law

Warrior Met Coal, LLC sued Eickhoff Corporation alleging certain pieces of heavy mining equipment Eickhoff had manufactured and sold to Warrior Coal were defective. Eickhoff subsequently moved the trial court to compel Warrior Coal to arbitrate its claims pursuant to an arbitration provision in contracts executed after the sale of the equipment, not the original purchase-order contracts associated with the allegedly defective equipment. The trial court denied the motion to compel arbitration and Eickhoff appeals. The Alabama Supreme Court determined the breach-of-warranty, breach-of-contract, and products-liability claims asserted by Warrior Coal in its action against Eickhoff were at least arguably connected to the master service agreements inasmuch as those contracts addressed Eickhoff's obligation to provide an employee to assist with the maintenance and operation of the longwall shearers (the allegedly defective equipment). Accordingly, because the parties also agreed in the master service agreements that the AAA commercial arbitration rules would govern any arbitration, and because those rules empowered the arbitrator to decide questions of arbitrability, the trial court erred when it instead at least implicitly resolved the arbitrability issue in favor of Warrior Coal in its order denying Eickhoff's motion to compel. That order was accordingly reversed and the case remanded for the trial court to enter an order granting Eickhoff's motion to compel arbitration and staying proceedings in the trial court during the pendency of the arbitration proceedings. View "Eickhoff Corporation v. Warrior Met Coal, LLC" on Justia Law

Alfa Insurance Corporation, ALFA Mutual General Insurance Corporation, ALFA Life Insurance Corporation, and ALFA Specialty Insurance Corporation (collectively, "Alfa") petitioned the Alabama Supreme Court for a writ of mandamus seeking review of an order entered by the Montgomery Circuit Court on December 18, 2015. Although Alfa set forth three issues for review, the Supreme Court reviewed only one: whether the circuit court had jurisdiction to enter the December 18, 2015, order and whether it exceeded its discretion by not setting that order aside. R.G. "Bubba" Howell, Jr., and M. Stuart "Chip" Jones were insurance agents for an Alfa insurance agency in Mississippi. Their agency agreements with Alfa included an arbitration provision, as well as a provision requiring Howell and Jones to purchase "errors and omissions" insurance coverage. In 2012, Alfa accused Howell and Jones of selling competing products in contravention of their agency agreements; Howell and Jones, however, alleged that their actions had been approved by Alfa. Regardless, Alfa forced Howell to resign his position as an Alfa agent on December 31, 2012, and discharged Jones on January 1, 2013. After review, the Supreme Court concluded the circuit court exceeded its discretion in entering the December 18, 2015, order compelling discovery pretermitted discussion of the other, two discovery issues. View "Ex parte Alfa Insurance Corporation et al." on Justia Law

Alfa Insurance Corporation, ALFA Mutual General Insurance Corporation, ALFA Life Insurance Corporation, and ALFA Specialty Insurance Corporation (collectively, "Alfa") petitioned the Alabama Supreme Court for a writ of mandamus seeking review of an order entered by the Montgomery Circuit Court on December 18, 2015. Although Alfa set forth three issues for review, the Supreme Court reviewed only one: whether the circuit court had jurisdiction to enter the December 18, 2015, order and whether it exceeded its discretion by not setting that order aside. R.G. "Bubba" Howell, Jr., and M. Stuart "Chip" Jones were insurance agents for an Alfa insurance agency in Mississippi. Their agency agreements with Alfa included an arbitration provision, as well as a provision requiring Howell and Jones to purchase "errors and omissions" insurance coverage. In 2012, Alfa accused Howell and Jones of selling competing products in contravention of their agency agreements; Howell and Jones, however, alleged that their actions had been approved by Alfa. Regardless, Alfa forced Howell to resign his position as an Alfa agent on December 31, 2012, and discharged Jones on January 1, 2013. After review, the Supreme Court concluded the circuit court exceeded its discretion in entering the December 18, 2015, order compelling discovery pretermitted discussion of the other, two discovery issues. View "Ex parte Alfa Insurance Corporation et al." on Justia Law

SCI Alabama Funeral Services, LLC, d/b/a Elmwood Cemetery and Mausoleum ("SCI"); Service Corporation International; SCI Funeral Services, LLC; Elmwood Cemetery Co.; Phyllis Pesseackey; and Jonathan Wheatley (collectively, "the defendants") appealed an order denying their motion to compel arbitration. The circuit court denied the motion to compel because it concluded that the relevant arbitration provision was unconscionable and thus unenforceable. In 2004, Johnnie Hinton ("Johnnie") signed a contract with SCI to purchase the interment rights to two burial spaces in Elmwood Cemetery. The contract contained an arbitration provision stating that "any claim" that Johnnie "may have" against SCI must be resolved by arbitration. In August 2016, Johnnie's husband, Nathaniel Hinton, passed away. Johnnie began to make arrangements to have Nathaniel buried in one of the two burial spaces to which she had acquired interment rights in 2004. SCI then informed Johnnie that someone else had mistakenly been buried in Nathaniel's space. According to Johnnie's complaint, the space she acquired for Nathaniel is next to the space where her father is buried. At Johnnie's request, SCI disinterred the deceased who was buried in the space Johnnie had acquired and buried him elsewhere so that Nathaniel could be buried in the space; Nathaniel was subsequently buried there. In September 2016, Johnnie sued SCI and the other defendants, alleging breach of contract and several other claims. The defendants moved to compel arbitration, citing the arbitration provision in the contract. Johnnie argued that the arbitration provision was unenforceable because, she said, the contract does not evidence a transaction affecting interstate commerce and the arbitration provision is unconscionable. The circuit court denied the motion to compel, concluding that the arbitration provision is unconscionable. Both substantive unconscionability and procedural unconscionability must be shown to establish unconscionability as a defense to an arbitration provision; these are separate, independent elements. The Alabama Supreme Court determined the arbitration provision in this case was not substantively unconscionable, and did not need to consider the issue of procedural unconscionability. The circuit court erred in denying the motion to compel arbitration. Therefore, the Court reversed the order and remanded the case for the circuit court to enter an order granting the motion to compel arbitration. View "SCI Alabama Funeral Services, LLC v. Hinton" on Justia Law