Marmet Health Care Center, Inc. v. Brown
The Supreme Court threw out a West Virginia rule that refused to enforce any pre-injury arbitration agreement in a nursing home contract when a patient later sued for personal injury or wrongful death, holding that the rule conflicted with the Federal Arbitration Act.
The unsigned ruling reminds state courts that once the Supreme Court has interpreted a federal law, they must follow that interpretation rather than carve out their own exceptions, and it sends the nursing home cases back to West Virginia to reconsider under ordinary contract law instead of a blanket anti-arbitration policy.
How it got here: A West Virginia trial court enforced arbitration in two cases; the state's highest court consolidated all three and ruled such agreements unenforceable, prompting the nursing homes to seek Supreme Court review.
The Case in Depth
What happened
Three West Virginia families sued nursing homes after relatives who required extensive care died, claiming negligence caused their injuries or deaths. In each case, a family member had signed an admission agreement on the patient's behalf that included a clause requiring disputes to be arbitrated rather than litigated in court.
The question before the Court
Could West Virginia refuse to enforce arbitration agreements in nursing home contracts whenever a patient later sued for personal injury or wrongful death?
Why it matters
Families who sign nursing home admission agreements containing arbitration clauses will generally have to arbitrate, not sue in court, even for injury or wrongful-death claims, unless an ordinary contract defense like unconscionability applies. The decision curbs states' ability to single out arbitration clauses for special disfavor in high-stakes, emotionally charged disputes like nursing home negligence.
What changes now
The case returns to the West Virginia Supreme Court of Appeals, which must decide whether the individual arbitration clauses are unenforceable under ordinary contract principles that apply to all contracts, not just arbitration agreements. This is a final ruling on the preemption question, but it leaves the case-specific unconscionability question open for the state court to resolve on remand.
What this does not decide
The Court did not decide whether the specific arbitration clauses in these nursing home contracts are enforceable. It left open whether ordinary, non-arbitration-specific state contract defenses, such as unconscionability, could still make particular clauses unenforceable, sending that question back for further review.
How the Court got there
The legal reasoning, step by step
- The Court applied the Federal Arbitration Act's basic command that written arbitration agreements involving interstate commerce are valid and enforceable except for the same legal reasons that would void any ordinary contract, with no built-in exception for personal-injury or wrongful-death claims.
- Under the Supremacy Clause of the Constitution, once the Supreme Court has interpreted a federal statute, state courts cannot adopt a conflicting reading or refuse to follow it, even if they disagree with the Court's reasoning.
- The Court found that West Virginia's rule flatly barring enforcement of arbitration clauses in nursing home contracts for injury or death claims was exactly the kind of categorical, claim-specific bar the Court had already said the arbitration law displaces.
- Because the state rule targeted arbitration clauses specifically rather than applying a neutral contract principle available to any agreement, it could not survive alongside the federal law's preemptive force.
- The Court left open whether the individual arbitration clauses might still be unenforceable under ordinary, non-arbitration-specific state contract defenses like unconscionability, since the lower court's unconscionability analysis may have been tainted by the invalid categorical policy.
Doctrinal impact
Cases affected by this decision
Reaffirms AT&T Mobility LLC v. Concepcion (563 U. S. ___)
The Court relied on this recent ruling that state laws banning arbitration of certain claims are displaced by federal law.