Marmet Health Care Center, Inc. v. Brown
United States Supreme Court
132 S. Ct. 1201, 565 U.S. 530 (2012)
- Written by Liz Nakamura, JD
Facts
Clayton Brown’s (defendant) relative was a resident of Marmet Health Care Center, Inc. (MHCC) (plaintiff), a West Virginia nursing home. After Brown’s relative passed away, Brown sued MHCC for negligence and wrongful death. Brown had previously signed a contract with MHCC containing a binding arbitration clause stating that Brown and MHCC must arbitrate all future disputes. The trial court dismissed Brown’s suit against MHCC based on the arbitration clause. Brown appealed. The Supreme Court of Appeals of West Virginia reversed, holding that (1) West Virginia law prohibited compelled arbitration for wrongful-death and negligence claims against nursing homes; (2) the Federal Arbitration Act (FAA) did not preempt the West Virginia law because the FAA did not apply to wrongful-death or negligence claims; and (3) even if the West Virginia law were preempted by the FAA, the arbitration clause in Brown’s contract with MHCC was void for unconscionability because it was against West Virginia public policy to apply binding arbitration clauses to wrongful-death and negligence claims against nursing homes. MHCC appealed to the United States Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Per curiam)
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