Oxford Health Plans LLC v. Sutter

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Arbitration
  • Date Filed: June 10, 2013
  • Case #: 12-135
  • Judge(s)/Court Below: Kagan, J., delivered the opinion for a unanimous Court. Alito, J., filed a concurring opinion, in which Thomas, J., joined.
  • Full Text Opinion

So long as an arbitrator makes a good faith attempt to interpret a contract, the arbitrator’s determination survives judicial review.

Respondent, a pediatrician, provided medical services for Petitioner, a healthcare insurance provider, under a fee-for-services contract which contained a binding arbitration clause. Respondent filed a class action suit in New Jersey Superior Court. Petitioner moved to compel arbitration, per the contract. The court granted Petitioner’s motion, and the suit moved to arbitration. Petitioner and Respondent agreed that the arbitrator should interpret their contract. The arbitrator determined that class arbitration was permissible under the contract.

Petitioner filed a motion in District Court to vacate the arbitrator’s decision, claiming that the arbitrator had “exceeded [his] powers” under §10(a)(4) of the Federal Arbitration Act (FAA), 9 U.S.C. §1 et. seq. The District Court denied the motion, and the Third Circuit affirmed.

Petitioner argued that under Stolt-Nielsen that “a party may not be compelled under the FAA to submit to class arbitration unless there is a contractual basis for concluding that the party agreed to do so.” Stolt-Nielsen v Animalfeeds International Co. 559 U. S., at 684.

The Supreme Court affirmed the Third Circuit and held that so long as an arbitrator “makes a good faith attempt” to interpret a contract, §10(a)(4) of the FAA defers to the arbitrator’s interpretation and decision, and the arbitrator’s determination survives judicial review.

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