Bison Building Materials, Ltd. v. Aldridge
422 S.W.3d 582
| Tex. | 2012Background
- Aldridge, an employee of Bison Building Materials, signed a Mutual Agreement to Arbitrate Claims governed by FAA interpretation.
- A post-injury waiver and release was signed in exchange for medical and wage benefits (~$80,000).
- Arbitration dismissed Aldridge's common-law claim based on the waiver; Aldridge challenged the award by seeking to set it aside.
- The trial court partially confirmed and partially vacated the arbitrator's award, noting unresolved fact questions about the waiver's enforceability and scope.
- The order did not expressly direct a rehearing, but identified remaining issues and effectively remanded for further fact-finding.
- The court of appeals dismissed the appeal for lack of jurisdiction; the parties and the supreme court analyzed appellate jurisdiction under the TAA and FAA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the trial court's order appealable as final or interlocutory? | Aldridge contends the order partially confirmed and vacated, disposing of at least part of the dispute. | Bison argues the order is not final and not appealable under Texas or federal provisions. | Interlocutory; not appealable under applicable statute. |
| Does the Texas Arbitration Act apply to this FAA arbitration about personal injury claims? | Aldridge relies on FAA-based review and mandamus as available state relief. | Bison emphasizes TAA limitations for personal injury arbitrations and lack of attorney-signature requirement. | TAA does not apply; jurisdiction governed by FAA and related Texas mandamus principles. |
| Does the order remand for unresolved fact questions render the award incomplete and unreviewable? | Aldridge argues unresolved questions prevented confirmation of the award. | Bison contends the order was a final determination on some issues with others remaining for arbitration. | Order is incomplete; remains interlocutory and not reviewable. |
Key Cases Cited
- Lehmann v. Har-Con Corp., 39 S.W.3d 191 (Tex. 2001) (finality standards for Texas judgments)
- CVN Group, Inc. v. Delgado, 95 S.W.3d 234 (Tex. 2002) (arbitral review and limited judicial review)
- Werline v. East Texas Salt Water Disposal Co., Inc., 307 S.W.3d 267 (Tex. 2010) (remand for clarification versus finalization; arbitral completeness)
- Forsythe International, S.A. v. Gibbs Oil Co. of Tex., 915 F.2d 1017 (5th Cir. 1990) (arbitration awards incomplete; need for remand)
- Rich v. Spartis, 516 F.3d 75 (8th Cir. 2008) (clarification remand; lack of finality in awards)
- Landy Michaels Realty Corp. v. Local 32B-32J, 954 F.2d 794 (2d Cir. 1992) (remand for damages; appellate lack of jurisdiction)
- Bull HN Info. Sys., Inc. v. Hutson, 229 F.3d 321 (1st Cir. 2000) (appealability when remand for new arbitration)
- Hall St. Assocs., L.L.C. v. Mattel, Inc., 552 U.S. 576 (U.S. 2008) (FAA cannot be expanded by agreement)