Marmet Health Care Center, Inc. v. Brown

Background

Three families sued nursing homes in West Virginia after patients died, alleging negligence. In each case a family member had signed an admission agreement for the patient that included a clause requiring arbitration of disputes. Two agreements mentioned paying arbitration filing fees; the third required arbitration but did not mention fees. A state trial court dismissed two suits based on those arbitration clauses. The State Supreme Court then held that West Virginia public policy forbade enforcing predispute arbitration clauses for nursing-home personal-injury or wrongful-death claims and rejected this Court’s prior interpretations of the Federal Arbitration Act as “tendentious.”

Reasoning

The Court asked whether the Federal Arbitration Act (FAA) covers these written admission agreements and whether a state rule that categorically bans arbitration of such claims conflicts with federal law. The Court explained that the FAA’s text contains no exception for personal-injury or wrongful-death claims and that federal law requires courts to enforce valid arbitration agreements. Because the West Virginia rule outlawed arbitration of a particular type of claim, it conflicted with the FAA and could not stand. The Court therefore vacated the state court’s judgment and sent the cases back for further proceedings consistent with this opinion.

Real world impact

State courts must follow the FAA and may not adopt a blanket rule forbidding predispute arbitration in nursing-home injury or death cases. On remand, the state court must consider whether the specific arbitration clauses are unenforceable for other state-law reasons that do not single out arbitration. The decision resolves the coverage question but leaves open ordinary contract or unconscionability defenses to be addressed on return to state court.