Justia Wyoming Supreme Court Opinion Summaries

Articles Posted in Arbitration & Mediation
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The Supreme Court reversed the judgment of the district court denying Wind River Rehabilitation and Wellness's motion to compel arbitration in this action alleging medical malpractice, holding that the district court erred in denying the motion to compel arbitration.Plaintiff, the wrongful death representative of Loy Forshee, filed this action against Wind River, where Forshee lived when he fell and broke his hip, alleging medical malpractice. Wind River moved to compel arbitration under the parties' arbitration agreement. The district court denied the motion, concluding that Wind River waived his right to arbitration by waiting fourteen months to compel arbitration. The Supreme Court reversed, holding that the record did not support a conclusion that Wind River waived its right to arbitrate. View "Empres at Riverton, LLC v. Osborne" on Justia Law

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The Supreme Court affirmed the judgment of the district court confirming an arbitration award involving a breach of a lease agreement after ruling that the arbitrator's determinations were not manifest error and were within his authority, holding that the district court did not err in confirming the arbitration award.Mountain Business Center, LLC (MBC) won an arbitration award against Fork Road, LLC. On appeal, MBC made three arguments in support of his request that the Court reverse and vacate the arbitration award. The Supreme Court affirmed, holding (1) the arbitrator did not exceed his authority by determining all issues presented by the parties in their stipulated list; (2) the arbitrator's determination that MBC was not the prevailing party and therefore not entitled to attorney fees was not a manifest error of law; and (3) the arbitrator's determination the MBC was not entitled to the first-to-breach rule was not a manifest error of law. View "Mountain Business Center, LLC v. Ford Road, LLC" on Justia Law

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The Supreme Court affirmed the order of the district court denying Robert Gill's motion to enforce a judgment confirming arbitration awards entered against Elizabeth Lockhart, holding that there was no error in the proceedings below.Siblings Robert Gill and Lockhart were the beneficiaries of a trust that owned land in Teton County. The trust decided to use the land to create a subdivision. This case concerned an arbitration award contained in an order covering the parties' rights and obligations regarding the subdivision. Gill successfully filed a petition asking the district court to confirm two of the arbitration awards. Thereafter, Gill filed his motion to enforce the judgment. The district court denied the motion, finding that Gill failed to prove some of his damages. The Supreme Court affirmed, holding that the district court did not abuse its discretion by not allowing Defendant to present certain evidence either at the evidentiary hearing or after the district court announced its oral ruling. View "Gill v. Lockhart" on Justia Law

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The Supreme Court denied Wyoming Cardiopulmonary Services's (WCS) motion to dismiss this appeal of the district court's confirmation of the decision of an arbitration panel concluding that the parties' non-compete agreement was enforceable if modified and reversed the confirmation of the panel's decision, holding that the panel made a manifest error of law.Dr. Michel Skaf, a cardiologist, signed a non-compete agreement when he became a shareholder in WCS. After WCS terminated Dr. Skaf for cause, he set up his own practice. WCS subsequently brought this complaint and a motion to compel arbitration. The panel found that the covenant not to compete was enforceable if modified and rewrote the agreement. The district court confirmed the panel's decision to enforce the covenant not to compete and entered judgment of $193,000. The Supreme Court reversed and vacated the award, holding that the panel made a manifest error of law in violation of public policy in its review and revision of the covenant not to compete. View "Skaf v. Wyoming Cardiopulmonary Services, P.C." on Justia Law

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The Supreme Court reversed the judgment of the district court granting Defendant's motion to compel arbitration under the "voluntary agreement for arbitration" Rick Miller signed on behalf of his mother, Julia Miller, after she was admitted to Life Care Center of Casper (LCCC), holding that Rick lacked authority to execute the agreement.After Julia died allegedly from injuries sustained during a series of mishaps at LCCC Rick filed this complaint stating claims of negligence and premises liability against Defendant. Defendant filed a motion to compel arbitration. The court granted the motion. The Supreme Court reversed, holding (1) Julia's durable power of attorney for health care did not grant Rick express actual authority to sign the arbitration agreement; (2) Julia did not hold Rick out as having apparent authority to sign the agreement; and (3) Rick was not authorized to execute the arbitration agreement as Julia's "surrogate" under the Wyoming Health Care Decisions Act, Wyo. Stat. Ann. 35-22-401 through 416. View "Miller v. Life Care Centers of America, Inc." on Justia Law

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The Supreme Court reversed the district court’s order denying Kindred Nursing and Rehabilitation - Wind River’s motion to compel arbitration in this wrongful death action. Aletha Boyd died following her discharge from Kindred. Aletha’s daughter, Susan Boyd, filed this action alleging that Kindred’s negligence in caring for Aletha caused her death. Kindred moved to compel arbitration pursuant to an alternative dispute resolution (ADR) agreement signed by Leanna Putman, Aletha’s other daughter and representative under a power of attorney at the time of Aletha’s admission into the nursing home. The district court denied the motion without providing reasons for doing so. The Supreme Court remanded with instructions to order arbitration as required by the ADR agreement, holding (1) Putnam had the authority to sign the ADR agreement on Aletha’s behalf; and (2) the ADR was neither unconscionable nor lacked mutuality of assent or sufficient consideration. View "Kindred Heathcare Operating, Inc. v. Boyd" on Justia Law

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This case involved an appeal from two district court orders, (1) an order regarding motions related to arbitration and (2) a decision and order over-ruling and denying any requested relief regarding defendants' objections to order regarding motions related to arbitration. In the first order, the district court granted appellee's motion to compel arbitration and stayed district court proceedings. In the second order, the district court overruled objections to the first order. At issue was whether the order compelling arbitration was a final, appealable order. After an examination of state court rules, state statutes, and the Federal Arbitration Act, the Supreme Court held that neither the first nor the second order was an appealable order and dismissed the appeal. View "Dennis v. Jack Dennis Sports, Inc." on Justia Law