Oxford Health Plans LLC v. Sutter
569 U.S. 564
| SCOTUS | 2013Background
- Sutter, a pediatrician, contracted with Oxford Health Plans to provide medical care to Oxford network members; Oxford agreed to pay at prescribed rates.
- Sutter sued in New Jersey state court on behalf of a proposed physician class alleging inadequate payments.
- The contract contained an arbitration clause mandating arbitration in New Jersey under the American Arbitration Association rules with one arbitrator.
- The arbitrator ruled that the agreement permitted class arbitration, triggering Oxford's § 10(a)(4) challenge.
- Stolt-Nielsen intervened during proceedings, prompting Oxford to seek reconsideration; the arbitrator reaffirmed class arbitration.
- The district court and Third Circuit denied vacatur; this Court granted certiorari to resolve the § 10(a)(4) standard and the arbitrator’s authority.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 10(a)(4) permits vacating an award that construes a contract to authorize class arbitration | Oxford: arbitrator exceeded powers by construing contract to permit class arbitration | Sutter: arbitrator properly construed contract, within delegated authority | No vacatur; arbitrator construed the contract, not exceeded powers |
Key Cases Cited
- Stolt-Nielsen S.A. v. AnimalFeeds Int'l Corp., 559 U.S. 662 (2010) (unavailable basis for class arbitration without contractual agreement; panel exceeded powers when imposing class proceedings without basis)
- Eastern Associated Coal Corp. v. Mine Workers, 531 U.S. 57 (2000) (arbitrator's construction of the contract is entitled to deference under § 10(a)(4))
- Paperworkers v. Misco, Inc., 484 U.S. 29 (1988) (limits on vacatur; arbitration interpretations of contract are insulated from merits review)
- First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938 (1995) (limits on vacatur to extraordinary circumstances; arbitration promotes swift resolution)
- Hall Street Assocs., L.L.C. v. Mattel, Inc., 552 U.S. 576 (2008) (reaffirmed narrow review standard for arbitration awards)
- Green Tree Fin. Corp. v. Bazzle, 539 U.S. 444 (2003) (gateway questions of arbitrability; not decisive here as parties delegated to arbitrator)