Monarch Consulting, Inc. v. National Union Fire Insurance Company of Pittsburg, PA

26 N.Y.3d 659, 47 N.E.3d 463, 27 N.Y.S.3d 97 (2016)

From our private database of 46,000+ case briefs, written and edited by humans—never with AI.

Monarch Consulting, Inc. v. National Union Fire Insurance Company of Pittsburg, PA

New York Court of Appeals
26 N.Y.3d 659, 47 N.E.3d 463, 27 N.Y.S.3d 97 (2016)

  • Written by Nicole Gray , JD

Facts

National Union Fire Insurance Company of Pittsburg, PA (defendant) issued workers’-compensation policies to three California-based employers: Monarch Consulting, Inc., Priority Business Services, Inc., and Source One Staffing, LLC (plaintiffs). In California, workers’-compensation insurance was regulated by the California Department of Insurance (the department) and its commissioner, along with the Workers’ Compensation Insurance Rating Bureau of California (WCIRB). Before insurers could issue workers’-compensation policies within the state, insurers had to file copies of all polices and endorsements with the department and WCIRB for review at least 30 days prior to issuance to ensure compliance. When filings were rejected, policies could not issue as initially filed. When agreements were made modifying obligations under the insurance agreement, the agreements had to be attached or made part of the policy. Before National issued the three workers’-compensation policies, National filed the required documentation. However, National did not file payment agreements that it entered with each of the insureds, extending them lines of credit by way of payment deferments in exchange for collateral. Unlike the policies themselves, the payment agreements contained arbitration clauses. When the payment agreements were entered, California law was silent regarding arbitration provisions in insurance policies. However, by the time disputes arose regarding the payment agreements, a state insurance-code provision had been enacted requiring insurers to disclose certain information about proposed arbitration agreements; otherwise, California law and forum were the default, but the law did not prohibit arbitration provisions. Three separate actions were filed where either Monarch, Priority Business, or Source One sought to stay arbitration or National sought to compel arbitration; a stay was granted in only one of the cases at the trial-court level. The three cases were consolidated on appeal, and the appellate division reversed the two cases that compelled arbitration, concluding that the McCarran-Ferguson Act (MFA) precluded application of the Federal Arbitration Act (FAA). National appealed.

Rule of Law

Issue

Holding and Reasoning (Stein, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 742,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 742,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,000 briefs, keyed to 986 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 742,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,000 briefs - keyed to 986 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership