Marmet Health Care Ctr., Inc. v. Brown - 565 U.S. 530, 132 S. Ct. 1201 (2012)

Rule:

West Virginia's prohibition against predispute agreements to arbitrate personal-injury or wrongful-death claims against nursing homes is a categorical rule prohibiting arbitration of a particular type of claim, and that rule is contrary to the terms and coverage of the Federal Arbitration Act, 9 U.S.C.S. § 1 et seq.

Facts:

Respondent family members brought three negligence suits against petitioner nursing homes in state court. In each case, a family member of a patient requiring extensive nursing care had signed an agreement with a nursing home on behalf of the patient. The contracts in two of the cases included a clause requiring the parties to arbitrate all disputes, other than claims to collect late payments owed by the patient. In each of the three cases, a family member of a patient who had died sued the nursing home in state court, alleging that negligence caused injuries or harm resulting in death. The Supreme Court of Appeals of West Virginia held unenforceable all predispute arbitration agreements that apply to claims alleging personal injury or wrongful death against nursing homes, and concluded that the Federal Arbitration Act (FAA), 9 U.S.C.S. § 1 et seq., did not preempt the state public policy. The nursing homes sought review.

Issue:

Was the state court correct in holding that the Federal Arbitration Act did not pre-empt the state’s public policy against predispute arbitration agreements that applied to claims of personal injury or wrongful death against nursing homes? 

Answer:

No.

Conclusion:

The United States Supreme Court determined that remand was warranted because the Supreme Court of Appeals of West Virginia's interpretation of the FAA was both incorrect and inconsistent with clear instruction in the precedents of the United States Supreme Court. West Virginia's prohibition against predispute agreements to arbitrate personal-injury or wrongful-death claims against nursing homes was a categorical rule prohibiting arbitration of a particular type of claim, and that rule was contrary to the terms and coverage of the FAA. The Court noted that the FAA’s text included no exception for personal-injury or wrongful-death claims. It required courts to enforce the bargain of the parties to arbitrate.