Caskey v. Sanford-Brown College
2012 Ohio 1543
Ohio Ct. App.2012Background
- McCaskey enrolled in Sanford-Brown College's cardiovascular sonography program in 2009 under an Enrollment Agreement that included an arbitration clause.
- The Agreement set forth tuition, program length, fees, and included cancellation, discrimination policies, and an arbitration provision.
- Sanford-Brown later sent transcripts to Cleveland Clinic/U University Hospitals; materials incorrectly stated he had failed and been expelled, though he actually graduated in September 2010.
- McCaskey sued Sanford-Brown and employee Cole; Sanford-Brown moved to stay proceedings pending arbitration and the trial court granted the stay.
- McCaskey challenged the arbitration provision as null, unconscionable, and inapplicable; the trial court stayed and this appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Enforceability of arbitration clause and stay authorization | McCaskey argues the stay/arbitration clause is invalid or inapplicable | Sanford-Brown asserts the clause is valid and properly covers the dispute; stay was mandatory under law | Arbitration clause enforceable; stay proper and case stayed pending arbitration |
Key Cases Cited
- Taylor Bldg. Corp. of Am. v. Benfield, 117 Ohio St.3d 352 (2008-Ohio-938) (unconscionability standard for arbitration clause applies to clause itself)
- Hayes v. Oakridge Home, 122 Ohio St.3d 63 (2009-Ohio-2054) (arbitration favored but unconscionability may preclude enforcement)
- Williams v. Aetna Fin. Co., 83 Ohio St.3d 464 (1998-Ohio-?) (context on unconscionability and contract terms)