Renfro Industries, Inc. v. Maria Rojas, 05-20-00555-CV

Background

Rojas lost part of three fingers in a workplace press accident and sued Renfro (and related entities) for negligence and fraud; the parties agreed to arbitration under an Election and Arbitration Agreement applying AAA rules.
The AAA hearing arbitrator ruled Rojas’s claim barred by limitations and issued a final award for Renfro on August 13, 2019 (including fee assessments).
Rojas timely served a written notice of appeal to the AAA; the agreement provides that once an appeal is timely served the hearing arbitrator’s award "shall no longer be considered final" for purposes of judicial enforcement.
A dispute arose over payment of the AAA appellate filing/administrative fees: AAA asked Renfro to pay the appellate filing fee; Renfro refused and claimed Rojas failed to perfect the appeal by not paying fees.
Renfro moved to confirm the arbitration award in state court; the trial court initially confirmed the award (Feb 25, 2020). Rojas moved for new trial, submitting evidence the AAA case remained active and that she sought a hardship waiver.
The trial court granted a new trial and vacated its prior confirmation; on appeal the court affirmed that the award was no longer final but reversed the trial court’s return of the case to the active docket and ordered remand to AAA for further proceedings.

Issues

Issue	Plaintiff's Argument (Rojas)	Defendant's Argument (Renfro)	Held
1. Whether the August 13, 2019 arbitration award was final and must be confirmed	Rojas: A timely served notice of appeal under the parties' agreement renders the award non-final and not subject to judicial confirmation	Renfro: The award is final because Rojas failed to perfect her appellate appeal by paying AAA fees; FAA §9 requiries confirmation absent FAA §10 grounds to vacate	Held: The agreement’s plain language controls: once an appeal is timely served the award is not final; court denied confirmation
2. Whether FAA vacatur grounds were required to deny confirmation	Rojas: Parties’ contract altered finality; contractual appeal tolls finality regardless of FAA §10 grounds	Renfro: Judicial review is narrowly cabined to FAA §10 grounds (e.g., evident partiality) before denying confirmation	Held: Contractual provision prevailed; denial of confirmation on the ground appeal was timely served was proper, so FAA §10 grounds were not required here
3. Whether the trial court erred by returning the case to its active docket (lifting stay and retaining merits)	Rojas: Renfro repudiated the arbitration by refusing to pay appellate fees, constituting default permitting return to court docket	Renfro: Court may not intervene in ongoing arbitral process; dispute over fees should be decided in arbitration; court must enforce arbitration agreement	Held: Trial court erred to return the case to its active docket because arbitration had commenced and AAA directed fee disputes to the appointed panel; remand to AAA ordered

Key Cases Cited

E. Tex. Salt Water Disposal Co. v. Werline, 307 S.W.3d 267 (Tex. 2010) (judicial review of arbitration awards is narrowly cabined)
Salas v. GE Oil & Gas, 857 F.3d 278 (5th Cir. 2017) (courts may not intervene in arbitral process beyond determining existence/enforceability of arbitration agreement)
Brown v. Dillard's, Inc., 430 F.3d 1004 (9th Cir. 2005) (failure to pay required arbitration fees can result in administrative closure or default when arbitration never proceeds)
Pre-Paid Legal Servs., Inc. v. Cahill, 786 F.3d 1287 (10th Cir. 2015) (party’s refusal to pay arbitration fees can justify lifting a judicial stay when arbitration is terminated for nonpayment)
Robinson v. Home Owners Mgmt. Enters., Inc., 590 S.W.3d 518 (Tex. 2019) (arbitration is a matter of contract and agreements must be enforced according to their terms)
Cambridge Legacy Grp., Inc. v. Jain, 407 S.W.3d 443 (Tex. App.—Dallas 2013) (order confirming or vacating an arbitration award reviewed de novo)