Taylor v. Extendicare Health Facilities, Inc.
147 A.3d 490
| Pa. | 2016Background
- FAA provides that arbitration agreements are valid, irrevocable, and enforceable subject to contract defenses.
- William Taylor, as Decedent’s representative, signed an ADR Agreement with Extendicare requiring arbitration of covered disputes.
- ADR Agreement states disputes between the parties shall be resolved in a single ADR process, including mediation and binding arbitration.
- Decedent died on April 3, 2012; Taylors filed wrongful death and survival claims against Extendicare and two other facilities.
- Trial court denied Extendicare’s motion to bifurcate and arbitration; Superior Court affirmed.
- Court held FAA preempts Rule 213(e) consolidating actions, requiring arbitration of the survival claim and remand for proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the FAA preempts Rule 213(e) to compel arbitration. | Taylors contend FAA preempts Rule 213(e) to permit arbitration of survival claim. | Extendicare argues Rule 213(e) blocks arbitration to consolidate in court. | Yes; FAA preempts Rule 213(e) and requires arbitration of the survival claim. |
| Whether consolidation for trial conflicts with FAA objectives. | Consolidation is unnecessary for arbitration of arbitrable claims. | Consolidation promotes efficiency; mixing arbitrable and non-arbitrable claims is awkward. | Conflict with FAA objectives favors enforcement and arbitration of arbitrable claims. |
Key Cases Cited
- Southland Corp. v. Keating, 465 U.S. 1 (1984) (federal policy favoring arbitration; states cannot require judicial forum for arbitrable claims)
- Moses H. Cone Mem’l Hosp. v. Mercury Constr. Corp., 460 U.S. 1 (1983) (arbitration as a federal policy; enables piecemeal resolution when necessary to enforce arbitration)
- Dean Witter Reynolds, Inc. v. Byrd, 470 U.S. 213 (1985) (FAA requires arbitration of pendent arbitrable claims even if inefficient in separate forums)
- Concepcion v. Cisco Systems, 563 U.S. 333 (2011) (FAA preempts state rules that obstruct arbitration; class-action waiver context)
- Marmet Health Care Ctr., Inc. v. Brown, 565 U.S. 530 (2012) (FAA preempts state categorical rules prohibiting arbitration of certain claims)