PacifiCare Health Systems v. Book
United States Supreme Court
538 U.S. 401, 123 S. Ct. 1531, 155 L. Ed. 2d 578 (2003)
- Written by Alexander Hager-DeMyer, JD
Facts
A group of physicians (physicians) (plaintiffs) contracted with several managed-healthcare organizations, including PacifiCare Health Systems, Inc., PacifiCare Operations, Inc., United-Healthcare, Inc., and United Health Group, Inc. (PacifiCare and United) (defendants). The contracts between the physicians and PacifiCare and United contained arbitration provisions stating that all contractual disputes would be arbitrated. The provisions also stated that punitive and exemplary damages would not be awarded in arbitration. The physicians filed suit in federal district court, alleging that PacifiCare and United failed to reimburse them for healthcare services provided to patients covered under PacifiCare’s and United’s health plans. The physicians filed claims under several federal and state laws, including the Racketeer Influenced and Corrupt Organizations (RICO) Act. PacifiCare and United moved to compel arbitration of the dispute, citing the arbitration provisions of the physicians’ contracts. The physicians opposed arbitration, arguing that they could not obtain meaningful relief in arbitration for their claims under the RICO Act, which provided for treble damages. The district court denied PacifiCare and United’s motion to compel arbitration, and the Eleventh Circuit affirmed on PacifiCare and United’s appeal. PacifiCare and United appealed to the United States Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Scalia, J.)
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