American Family Life Assurance v. Glenda Biles, et
714 F.3d 887
| 5th Cir. | 2013Background
- Arbitration clause in Aflac insurance policy at issue; district court granted summary judgment compelling arbitration.
- Decedent David Biles allegedly signed both the policy application and arbitration acknowledgment form; Aflac asserts signatures are authentic.
- Policy issued Jan 1, 2007; death benefits paid to decedent’s mother Glenda Biles and decedent’s roommate Ashley.
- Appellants (Ms. Biles and siblings) filed Mississippi state court suit seeking to challenge benefits paid to Ashley; Aflac moved to compel arbitration under FAA §4 in federal court.
- Federal action sought to compel arbitration against Aflac and its agents; district court held evidentiary issues (Daubert/affidavits) and discovery thresholds before ruling; summary judgment ultimately granted in Aflac’s favor.
- Final judgment and order compelled arbitration, with a Rule 54(b) certification and appeal filed by Appellants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Colorado River abstention was proper | Appellants contend abstention due to parallel state proceedings | Federal action is not parallel and exceptional circumstances don’t exist | Abstention denied; district court correctly exercised jurisdiction |
| Anti-Injunction Act bar | Arbitration order should be barred as stay of state proceedings | Arbitration order falls within injunctions necessary to protect or effectuate judgment | Not barred; exception applied; arbitration order upheld |
| Rule 56(d) discovery denial | Additional discovery would defeat summary judgment | Discovery unlikely to affect the dispositive issue of forgery; timely denial appropriate | No abuse of discretion; denial affirmed |
| Whether Ms. Giles’s affidavit creates a material fact issue | Giles’s affidavit disputes signature authenticity | affidavit not properly submitted to record; cannot create issue of fact | Giles’s affidavit not part of summary-judgment record; no genuine issue created |
Key Cases Cited
- Brown v. Pac. Life Ins. Co., 462 F.3d 384 (5th Cir. 2006) (abstention factors and parallel proceedings standards)
- Stewart v. W. Heritage Ins. Co., 438 F.3d 488 (5th Cir. 2006) (parallelism and abstention analysis; six-factor test)
- Moses H. Cone Mem. Hosp. v. Mercury Constr. Co., 460 U.S. 1 (1983) (abstention framework and discretion to refuse abstention)
- Snap-on Tools Corp. v. Mason, 18 F.3d 1261 (5th Cir. 1994) (FAA §4 questions governed by federal law; standard for arbitration)
- Am. Heritage Life Ins. Co. v. Orr, 294 F.3d 702 (5th Cir. 2002) (arbitration-issue finality; injunction considerations)