AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The cases involve claims for wrongful death, negligence, joint and several liability, and punitive damages against sixteen healthcare facilities and their affiliates by the personal representatives of the wrongful death estates of Agripina Bustamante and Antolino Jacquez. The decedents were staying at the defendant facilities at their times of death. Family members signed voluntary arbitration agreements on behalf of the decedents during intake at each facility. The complaints allege that the defendants failed to properly diagnose symptoms and prevent injuries leading to the wrongful deaths (para 2).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiffs: Argued that the district courts had the authority to make threshold arbitrability determinations and that the arbitration agreements were substantively unconscionable due to a provision limiting all damage awards to 300 percent of compensatory damages. In Bustamante, it was also argued that the defendants could not avail themselves of the arbitration agreement due to a failure to make a timely demand for arbitration before the statute of limitations expired (paras 3-4).
• Defendants: Contended that the district courts erred in making threshold determinations about the arbitrability of the claims contrary to the expressed intent in the arbitration agreements. They also argued that any findings of substantive unconscionability were incorrect (para 1).

Legal Issues

• Whether the district courts exceeded their authority in making threshold arbitrability determinations under the arbitration agreements.
• Whether the arbitration agreements were substantively unconscionable due to the damage limitation provision.

Disposition

• The Court of Appeals reversed the district courts' determinations that they had the authority to make threshold arbitrability determinations and remanded the cases to be submitted to arbitration (para 1).

Reasons

• The Court of Appeals, per Judge J. Miles Hanisee, with Judges Jacqueline R. Medina and Katherine A. Wray concurring, found that the arbitration agreements clearly delegated threshold matters of arbitrability to arbitration. The court determined that the delegation provisions in the agreements provided clear and unmistakable evidence that the parties intended to delegate such threshold issues to an arbitrator. The court also found that the plaintiffs did not specifically challenge the delegation clause, which would have been necessary to give the district courts authority to make threshold determinations. In the case of Bustamante, the court noted that the challenge to the delegation provision appeared to be a claim that the arbitration agreement as a whole was breached by the defendant's untimely demand for arbitration, which is not a specific attack on the delegation clause. In the case of Jacquez, the court found that the challenge to the alleged substantive unconscionability of the damage limitation provision did not specifically undermine the delegation clause. Therefore, the court concluded that the district courts erred in determining they had the authority to decide on the threshold issues and remanded both cases to be submitted to arbitration (paras 5-15).