Mountain View Health & Rehabilitation Center, Inc., Creative Solutions in Healthcare, Inc., and Lidia Moya v. Mary Horton Keele
08-23-00033-CV
Tex. App.Jun 17, 2024Background
- Mary Horton Keele sued Mountain View Health & Rehabilitation Center, Creative Solutions in Healthcare, and Lidia Moya ("Premises Parties"), alleging she suffered injuries from a slip and fall while employed at their facility.
- Keele admitted she signed an arbitration agreement upon employment, but the agreement only identified her employer as "the facility," without further specificity.
- The Premises Parties moved to compel arbitration based on this agreement, arguing all workplace injury claims are subject to arbitration.
- Keele challenged the agreement's validity, arguing that the failure to specifically identify her employer on its face created ambiguity and showed no "meeting of the minds."
- The trial court denied the motion to compel arbitration, prompting the Premises Parties to appeal.
- On appeal, the Court focused on both the signed agreements and Keele's own pleadings, which identified the Premises Parties as her employer.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Authentication of documents | Keele: Docs were not authenticated below, so not enforceable. | Premises Parties: Keele admitted signing, authentication thus not at issue. | Held: Authentication challenge fails due to Keele's admission of her signature. |
| Identity of contracting party | Keele: Agreement didn't clearly state employer's name, so no meeting of minds. | Premises Parties: Pleadings & facts show Mountain View was employer; specificity enough | Held: Identity of "the facility" clear from pleadings; Keele can't dispute after suit. |
| Four corners rule / ambiguity | Keele: Ambiguity in "facility" made agreement unenforceable. | Premises Parties: Name not required; context and pleadings clarify meaning. | Held: No ambiguity; context/pleadings clarify "facility" as the employer. |
| Arbitration enforceability | Keele: No valid agreement; defenses (e.g., unconscionability). | Premises Parties: Valid agreement exists, no valid defenses. | Held: Agreement enforceable; defenses not preserved or unmeritorious. |
Key Cases Cited
- In re Odyssey Healthcare, Inc., 310 S.W.3d 419 (Tex. 2010) (party seeking arbitration must show valid agreement exists)
- In re Whataburger Restaurants LLC, 645 S.W.3d 188 (Tex. 2022) (arbitration agreements interpreted under contract law principles)
- Rachal v. Reitz, 403 S.W.3d 840 (Tex. 2013) (signed contract presumes assent)
- Lake Jackson Med. Spa, Ltd. v. Gaytan, 640 S.W.3d 830 (Tex. 2022) (pleadings may be binding as judicial admissions)
- In re Macy’s Tex., Inc., 291 S.W.3d 418 (Tex. 2009) (employee can't avoid arbitration by disputing employer’s precise legal name in agreement)