Transfer of Structured Settlement Payment Rights ex rel. Saucier v. Saucier, 130 So. 3d 1108

Saucier settled a personal-injury claim and entered a structured settlement with Aviva; two scheduled payments totaling $350,000 (Assigned Payments) were at issue.
Saucier later transferred the Assigned Payments to Woodbridge Investments LLC for $220,000; Mississippi MSSPA proceedings approved this transfer via a Transfer Order.
Woodbridge did not fund the transfer; it referred Saucier to RSL Funding LLC, which later entered an Amended Transfer Agreement to transfer to RSL.
Amended Order I (Feb. 6, 2009) approved the transfer to RSL; Amended Order II (Mar. 12, 2009) removed BOI as payee and designated RSL as sole assignee; the Stipulation governing this transfer designated Massachusetts law and contained no arbitration clause.
RSL’s efforts to enforce arbitration were challenged by Saucier; MSSPA notice requirements were allegedly not met, and the transfer was ultimately deemed not effective; the chancery court issued injunctions and denied RSL’s arbitration relief, remanding damages and Rule 11 issues for later proceedings.
This appeal concerns whether the chancellor properly denied arbitration and granted permanent injunctive relief, with damages under Rule 11 to be addressed on remand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the transfer to RSL effective under MSSPA, making arbitration enforceable?	Saucier argues the MSSPA required notice and funding; the transfer to RSL was not valid.	RSL contends the Amended Transfer Agreement and Orders validly approved the transfer and invoked arbitration.	No; the transfer was not effective under MSSPA, so arbitration provisions were not enforceable.
Should the court stay proceedings and compel arbitration based on the asserted arbitration clauses?	Saucier argues the arbitration clause should control via separability and MSSPA validity.	RSL seeks to stay court proceedings and refer to arbitration under FAA and MSSPA.	Denied; the chancellor properly denied stay and issued a permanent injunction against arbitration.

Symetra Life Ins. v. Rapid Settlements, Ltd., 567 F.3d 754 (5th Cir. 2009) (arbitration cannot effect a transfer when MSSPA approval is lacking)
Sawyers v. Herrin-Gear Chevrolet Co., 26 So.3d 1026 (Miss. 2010) (final decision on arbitration appellate jurisdiction under Miss. rules)
East Ford, Inc. v. Taylor, 826 So.2d 709 (Miss. 2002) (rigorous enforcement of arbitration agreements; public policy favoring arbitration)