Gotham Holdings, LP v. Health Grades, Inc.
United States Court of Appeals for the Seventh Circuit
580 F.3d 664 (2009)
- Written by Tammy Boggs, JD
Facts
Health Grades, Inc. (defendant) and Hewitt Associates, LLC (Hewitt) submitted a dispute to confidential arbitration. Health Grades and Hewitt agreed to maintain the proceeding as confidential and not to disclose any matter or information related to the arbitration unless required to do so in response to a subpoena or other legal process. The dispute was resolved by an arbitration award. Subsequently, Health Grades became involved in litigation with Gotham Holdings, LP (Gotham) (plaintiff) in federal district court. Health Grades argued that its arbitration award in the dispute with Hewitt supported Health Grades’ case on the merits. In turn, Gotham sought discovery from Health Grades on the arbitration matter. Health Grades objected, arguing that it had pledged confidentiality to Hewitt. Gotham then served a subpoena on Hewitt, seeking documents related to the arbitration, and moved to enforce the subpoena. The district court ordered Hewitt to comply with the subpoena. Health Grades appealed. Hewitt was willing to comply with the subpoena, but Health Grades argued that its confidentiality agreement with Hewitt should be respected.
Rule of Law
Issue
Holding and Reasoning (Easterbrook, C.J.)
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