AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• In July 2018, Plaintiff Beatrice Juarez was admitted to Sunset Villa care facility for rehabilitation following knee replacement surgery. As part of her admission, she signed an "Admission Agreement" and an arbitration agreement titled "Agreement for Dispute Resolution Program" (DRP). The DRP required disputes to be resolved through arbitration, waiving the right to a judge or jury, and included provisions for the payment of arbitration fees and attorney fees by the Defendant. Approximately seven months later, Plaintiff filed a complaint against Sunset Villa alleging medical negligence and related claims (paras 2-6).

Procedural History

• District Court of Santa Fe County: Denied Defendant's motion to compel arbitration, citing lack of evidence on the reasonableness of the arbitration provision, failure to contradict Plaintiff's affidavit, potential supersession of the DRP by the Admission Agreement, and lack of consideration if the DRP was signed after the Admission Agreement (para 9).

Parties' Submissions

• Plaintiff: Argued that the DRP was both substantively and procedurally unconscionable due to unfair provisions and the circumstances under which the agreement was signed. Plaintiff also challenged the delegation clause under the same grounds as the DRP itself (paras 7, 9).
• Defendant: Asserted that the DRP was a valid, enforceable agreement supported by consideration, and that the delegation clause required any questions about arbitrability to be submitted to the arbitrator. Defendant also argued that Plaintiff failed to specifically challenge the delegation clause and failed to establish both procedural and substantive unconscionability (paras 6, 8).

Legal Issues

• Whether the district court erred in denying the motion to compel arbitration on contract validity grounds.
• Whether the delegation clause in the DRP clearly and unmistakably delegates questions of arbitrability to the arbitrator.
• Whether Plaintiff specifically challenged the delegation clause (paras 10-11, 20-22, 28).

Disposition

• The Court of Appeals reversed the district court's decision and remanded with instructions to enter an order compelling arbitration (para 41).

Reasons

• The Court of Appeals found that the district court erred in denying the motion to compel arbitration on contract validity grounds, as the DRP was supported by consideration and should be construed together with the Admission Agreement as one instrument. The Court also held that the delegation clause clearly and unmistakably delegated questions of arbitrability to the arbitrator and that Plaintiff did not specifically challenge the delegation clause. The Court applied principles of New Mexico contract law and the New Mexico Uniform Arbitration Act, emphasizing the importance of adhering to agreements for non-judicial dispute resolution (paras 13-19, 23-27, 29-40).