Linde Health Care Staffing, Inc. v. Claiborne County Hospital
198 So. 3d 318
| Miss. | 2016Background
- Linde obtained a Missouri arbitration award and converted it to a Missouri judgment after claiming Patient’s Choice (a private lessee) owed unpaid invoices for temporary physicians.
- The written contract Linde relied on named “Claiborne County Hospital” on page one but was signed by Tim Cockrell as CEO of Patient’s Choice, with “Patient’s Choice” handwritten as the client on the signature page.
- Linde sent arbitration demands first to Patient’s Choice’s CEO and later to Claiborne County officials; the County’s attorney notified Linde that the contract was with Patient’s Choice and that Cockrell lacked authority to bind the County.
- The arbitrator entered an award in Missouri against “Claiborne County Hospital” after the hospital did not appear; Missouri confirmed the award and Linde enrolled the foreign judgment in Claiborne and Madison Counties, Mississippi.
- Both Mississippi circuit courts granted the Hospital’s Rule 60(b) motions to set aside enrollment, finding Mississippi need not give full faith and credit because the Missouri court lacked personal jurisdiction over the Hospital (it was not a contracting party), and the judgment was obtained by misrepresentation.
- The Mississippi Supreme Court affirmed, holding the Federal Arbitration Act’s (FAA) procedural time limit does not bind an entity that never agreed to arbitrate or contractually submitted to arbitration.
Issues
| Issue | Linde's Argument (Plaintiff) | Claiborne County Hospital's Argument (Defendant) | Held |
|---|---|---|---|
| Whether the FAA’s 90‑day vacatur period bars a collateral Rule 60(b) attack on a foreign judgment confirming an arbitration award | FAA controls; Hospital should have moved to vacate within 90 days, so Rule 60(b) attack is time‑barred | Hospital never contracted with Linde and so is not bound by the FAA or its time limits | FAA time limit does not apply to an entity that never agreed to arbitrate; Rule 60(b) challenge was timely/available |
| Whether Missouri had personal jurisdiction over Claiborne County Hospital for the arbitration/confirmation | The Missouri confirmation is entitled to full faith and credit; jurisdiction presumed | Hospital was not a party to the contract/arbitration; Cockrell signed for Patient’s Choice; County never authorized contract | Missouri lacked personal jurisdiction over the Hospital; judgment need not be recognized |
| Whether the Hospital met its burden to overcome the presumption that the sister‑state judgment is valid | Linde: Hospital failed to affirmatively prove invalidity | Hospital produced the lease showing Patient’s Choice leased and operated the hospital and the contract signature evidence | Hospital met its burden with admissible extrinsic proof; Rule 60(b) relief appropriate |
| Whether ambiguity in the contract prevents setting aside the foreign judgment | Contract ambiguity precludes clear proof Hospital wasn't contracting party | Extrinsic evidence (lease, signature) resolves ambiguity in favor of Patient’s Choice as contracting party | Ambiguity resolved by extrinsic evidence; contract was with Patient’s Choice, not the Hospital |
Key Cases Cited
- AT&T Techs., Inc. v. Communications Workers of Am., 475 U.S. 643 (arbitration is a matter of contract; courts decide arbitrability)
- Steelworkers v. Warrior & Gulf Navigation Co., 363 U.S. 574 (parties cannot be compelled to arbitrate disputes they did not agree to submit)
- International Union of Operating Eng’rs, Local 150 v. Rabine, 161 F.3d 427 (7th Cir.) (time limits do not bind non‑contracting third parties)
- Sheet Metal Workers Int’l Ass’n v. Arizona Mechanical & Stainless, Inc., 863 F.2d 647 (9th Cir.) (arbitrability is for the court to decide; nonparties not bound)
- Frances Hosiery Mills, Inc. v. Burlington Indus., Inc., 204 S.E.2d 834 (N.C. 1974) (sister‑state arbitration confirmation not entitled to full faith and credit where defendant never agreed to arbitrate)
- Galbraith & Dickens Aviation Ins. Agency v. Gulf Coast Aircraft Sales, Inc., 396 So. 2d 19 (Miss. 1981) (burden on party attacking sister‑state judgment to show invalidity)
- Reeves Royalty Co. v. ANB Pump Truck Serv., 513 So. 2d 595 (Miss. 1987) (Rule 60(b) is appropriate to challenge enrollment of a foreign judgment)