Justia Texas Supreme Court Opinion SummariesArticles Posted in Arbitration & Mediation
Aerotek, Inc. v. Boyd
The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court denying Aerotek, Inc.'s motion to compel arbitration, holding that an alleged signatory's simple denial that he signed the record was insufficient to prevent attribution of an electronic signature to him.Plaintiffs, four individuals, were hired by Aerotek to work as contractors on a construction project. After all four were terminated, they sued Aerotek and others for racial discrimination and retaliation. Aerotek moved to compel arbitration based on an online-only hiring application that each employee had completed. Plaintiffs opposed the motion, arguing that they had completed the online hiring application but denying that they had ever seen or signed a mutual arbitration agreement (MAA) within the application. The trial court denied the motion to compel arbitration. The court of appeals affirmed, rejecting Aerotek's argument that it had conclusively established the validity of the MAAs. The Supreme Court reversed, holding (1) Aerotek conclusively established that Plaintiffs signed, and therefore consented to, the MAAs; and (2) therefore, the trial court erred in denying Aerotek's motion to compel arbitration. View "Aerotek, Inc. v. Boyd" on Justia Law
Wagner v. Apache Corp.
The Supreme Court affirmed the judgment of the court of appeals reversing the decision of the trial court concluding that indemnity claims fell within an exception to an arbitration clause and that the non-signatory assignees were bound by the agreement under a theory of assumption, holding that Plaintiffs' request for a declaratory judgment was subject to mandatory arbitration.As president of Wagner Oil Company, Bryan Wagner signed a purchase and sale agreement (PSA) purchasing several assets from Apache Corporation. The PSA contained an indemnification provision and an arbitration clause. Later, third-party surface landowners filed lawsuits against Apache, seeking damages for alleged environmental contamination caused by Apache's operation of the assets before they were sold. Apache filed a demand for arbitration against Plaintiffs, including Wagner Oil and Wagner, for indemnity and defense. Plaintiffs then filed a declaratory judgment action seeking a declaration that Plaintiffs were not parties to the PSA and therefore not subject to the arbitration and indemnity clauses. The trial court denied Apache's motion to compel arbitration. The court of appeals reversed. The Supreme Court affirmed, holding (1) the indemnity disputes over third party-claims fall within the scope of the arbitration clause and outside its exception; and (2) the Wagner Oil signees were bound by the arbitration clause. View "Wagner v. Apache Corp." on Justia Law
In re Copart, Inc.
The Supreme Court conditionally granted mandamus relief in this arbitration dispute, holding that the trial court abused its discretion in determining that pre-arbitration discovery was warranted in this case.After Plaintiff's employment was terminated she sued Defendant, her former employer, claiming discrimination and retaliation. Defendant moved to compel arbitration pursuant to the company's employee handbook acknowledgment and agreement, which contained an arbitration agreement. At issue was Plaintiff's second motion to compel pre-arbitration discovery claiming that an enforceable arbitration agreement did not exist. After the trial court granted the motion Defendant sought mandamus relief. The court of appeals denied the motion. The Supreme Court conditionally granted mandamus relief, holding that the trial court clearly abused its discretion in ordering pre-arbitration discovery because Plaintiff failed to provide the trial court with a reasonable basis to conclude that it lacked sufficient information to determine whether her claims were arbitrable. View "In re Copart, Inc." on Justia Law
Bonsmara Natural Beef Co. v. Hart of Texas Cattle Feeders, LLC
In this cattle-feeding dispute, the Supreme Court affirmed the judgment of the court of appeals overturning the trial court's denial of Appellees' post-judgment motion to compel arbitration, holding that a party does not forfeit its right to challenge a ruling on appeal from a final judgment simply by choosing not to pursue an interlocutory appeal of that ruling.Appellants brought this action alleging fraud, unjust enrichment, and other claims. Appellees moved to dismiss the suit and compel arbitration, arguing that the claims were subject to the agreement's arbitration clause. The trial court denied the motion, and Appellees did not challenge the court's ruling through an interlocutory appeal. After the trial court rendered judgment Appellees appealed, arguing that the trial court erred when it denied their motion to compel arbitration. The court of appeals reversed and remanded with instructions that the trial court order the parties to arbitration. The Supreme Court affirmed, holding (1) the court of appeals had jurisdiction to consider the trial court's denial of Appellees' motion to compel arbitration; and (2) on the merits, the court of appeals did not err in ordering arbitration. View "Bonsmara Natural Beef Co. v. Hart of Texas Cattle Feeders, LLC" on Justia Law
San Antonio River Authority v. Austin Bridge & Road, L.P.
In this construction contract dispute, the Supreme Court held that the San Antonio River Authority possessed the authority to agree to arbitrate claims under Texas Local Government Code Chapter 271 and exercised that authority in the contract and that the judiciary, rather than an arbitrator, retains the duty to decide whether a local government has waived its governmental immunity.The River Authority hired Austin Bridge and Road L.P. for a construction project. The parties agreed to submit any disputes about the contract to arbitration. Austin Bridge invoked the contract's arbitration provisions when disagreements about the scope of work and payment arose. After the arbitrator denied the River Authority's plea of governmental immunity, the River Authority sued Austin Bridge, arguing that it lacked the authority to agree to the contract's arbitration provisions. The trial court concluded that the arbitration provisions in the contract were enforceable. The court of appeals agreed that the River Authority had the authority to agree to arbitrate but concluded that a court, rather than an arbitrator, must decide whether the River Authority was immune from the claims against it. The Supreme Court affirmed, holding that chapter 271 waived the River Authority's immunity from suit for Austin Bridge's breach of contract claim. View "San Antonio River Authority v. Austin Bridge & Road, L.P." on Justia Law
Robinson v. Home Owners Management Enterprises, Inc.
The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court declining to compel arbitration of class claims under the parties' agreement in this case, holding that the lower courts applied the correct legal standards in declining to compel class arbitration.This arbitration dispute between homeowners and their home warranty company evolved into a putative class action complaining about releases the warranty allegedly demanded before making covered repairs. Plaintiffs demanded arbitration, asserting that Defendant was required to arbitrate the class claims under the arbitration provisions in the warranty. The trial court granted Defendant's motion to dismiss, concluding that the question of whether the parties agreed to class arbitration was a question of arbitrability for the court to make and that the warranty agreement did not permit class arbitration. The court of appeals affirmed. The Supreme Court affirmed, holding (1) arbitratibility of class claims is a gateway issue for the court unless the arbitration agreement clearly and unmistakably expresses a contrary intent; (2) an agreement to arbitrate class claims cannot be inferred from silence or ambiguity, but rather, an express contractual basis is required; and (3) the lower courts correctly determined that Defendant was not bound to arbitrate Plaintiffs' putative class claims. View "Robinson v. Home Owners Management Enterprises, Inc." on Justia Law
RSL Funding, LLC v. Newsome
The Supreme Court reversed the judgment of the court of appeals affirming the trial court’s denial of a motion to compel arbitration of a dispute over which of two orders approving a transfer of a payee’s structured-settlement-payment rights to another under the Structured Settlement Protection Act, Tex. Civ. Prac. & Rem. Code 141.004, controlled, holding that the court of appeals erred in determining that the dispute was one that could not be arbitrated.Specifically, the court of appeals concluded that the dispute over which order controlled was not an arbitrable issue even where an arbitration agreement included in the transfer agreement assigned issues of arbitrability to the arbitrator. The Supreme Court reversed, holding that because the parties agreed to have the arbitrator decide issues of arbitrability and because the courts below did not question the validity of the parties’ arbitration clause, this dispute must be sent to arbitration for the arbitrator to at least decide arbitrability. View "RSL Funding, LLC v. Newsome" on Justia Law
Posted in: Arbitration & Mediation
Stines v. Jefferson County, Texas
Jefferson County v. Jefferson County Constables Ass’n, __ S.W.3d __, __ (Tex. 2018), in which the Supreme Court held that the Fire and Police Employee Relations Act applies to deputy constables because they qualify as “police officers” under the Act’s definition of that term, resolved the issue presented in this case and necessitated reversal of the court of appeals’ judgment.Petitioner was terminated from his employment as a deputy constable in Jefferson County and sued for a declaratory judgment and a writ of mandamus seeking to compel the County to participate in a binding arbitration under the terms of the applicable collective bargaining agreement between the County and its deputy constables’ bargaining association. The trial court granted Petitioner’s requests and ordered the parties to participate in binding arbitration. The court of appeals dismissed the case for want of jurisdiction, holding that deputy constables are not “police officers” under the Act and have no right to bargain collectively with their public employers. The Supreme Court reversed in part and remanded this case for further proceedings, holding that this issue was definitively resolved against the County in Jefferson County. View "Stines v. Jefferson County, Texas" on Justia Law
Jody James Farms, JV v. Altman Group, Inc.
The lower courts in this case erred by requiring a signatory to arbitrate its non-contractual claims against non-signatories.Jody James Farms, JV purchased a crop revenue coverage insurance policy from Rain & Hail, LLC through the Altman Group. The insurance policy contained an arbitration clause. Neither the Altman Group nor any of its employees signed the agreement. After Rain & Hail denied coverage for a grain sorghum crop loss suffered by Jody James and the parties arbitrated the dispute, Jody James sued the Altman Group and its agent (collectively, the Agency) for breach of fiduciary duty and deceptive trade practices. The Agency successfully moved to compel arbitration under the insurance policy. At arbitration, Jody James asserted that it had a right to proceed in court against the Agency because the Agency was a non-signatory to the arbitration agreement. The arbitrator resolved that issue and the merits of the dispute in the Agency’s favor. The trial court confirmed the award. The court of appeals affirmed. The Supreme Court reversed because (1) Jody James and the Agency did not agree to arbitrate any matter; and (2) Jody James may not be compelled to arbitrate under agency, third-party-beneficiary, or estoppel theories. View "Jody James Farms, JV v. Altman Group, Inc." on Justia Law
Jefferson County v. Jefferson County Constables Ass’n
In this dispute governed by a collective bargaining agreement between a county and its deputy constables, the Supreme Court affirmed the judgment of the court of appeals ruling that deputy constables are “police officers” entitled to enter into collective bargaining agreements (CBAs) with their public employers under Tex. Loc. Gov’t Code Ann. 174 and that the arbitrator did not exceed his authority in awarding relief to the deputy constables.The county petitioned to vacate the arbitrator’s award, arguing that the arbitrator exceeded his authority in concluding that the county violated the CBA by eliminating several deputy constable positions without regard to seniority and ordering the county to reinstate the deputies in order of seniority. The trial court granted the county’s motion for summary judgment and rendered final judgment in its favor. The court of appeals reversed. The Supreme Court affirmed, holding that deputy constables are “police officers” under the CBA, that the CBA was valid and enforceable, and that the arbitrator did not exceed his authority in ordering the deputies’ reinstatement on a seniority basis. View "Jefferson County v. Jefferson County Constables Ass’n" on Justia Law