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

• Marlene Urbina, acting under a general power of attorney for her mother, Dolores Figueroa, sought to admit her mother to Casa Arena Blanca, a nursing home operated by THI of New Mexico at Casa Arena Blanca, LLC (THICAB). As a condition of Ms. Figueroa's admission, Ms. Urbina was required to sign various admission agreements, including an arbitration agreement. The agreement stated that signing it was a precondition for admission or medical treatment at the facility. After Ms. Figueroa's admission, her health rapidly declined, leading to her death. Her son, Didier Figueroa, filed a complaint against THICAB, alleging wrongful death and other claims related to the care provided (paras 2-3).

Procedural History

• District Court of Santa Fe County: The arbitration agreement was found to be substantively unconscionable and unenforceable, aligning with the Supreme Court's stance in Cordova v. World Finance Corporation of New Mexico (para 5).

Parties' Submissions

• Plaintiff: Argued that the arbitration agreement was substantively unconscionable because it was unfairly one-sided in favor of the nursing home, binding the resident to arbitration in almost all instances where the resident and their family would be suing the nursing home (para 5).
• Defendant: Contended that the Federal Arbitration Act (FAA) preempts state law applying a substantive unconscionability analysis to arbitration agreements, that the agreement was not unfairly one-sided, and that even if parts of the agreement were unconscionable, the rest should be enforced (para 7).

Legal Issues

• Whether the arbitration agreement required by the nursing home as a condition of admission is substantively unconscionable.
• Whether the Federal Arbitration Act preempts state law that applies a substantive unconscionability analysis to the terms of arbitration agreements.
• Whether the unconscionable parts of an arbitration agreement can be severed to enforce the remainder of the agreement (paras 7-8, 36).

Disposition

• The district court's decision that the arbitration agreement is substantively unconscionable and unenforceable was affirmed (para 42).

Reasons

• The Court of Appeals, per Judge Michael E. Vigil, with Judges Michael D. Bustamante and Timothy L. Garcia concurring, held that the arbitration agreement was substantively unconscionable because it was unreasonably one-sided in favor of the nursing home. The agreement required almost all disputes to be resolved through arbitration, significantly limiting the resident's ability to seek judicial redress. The court found that the Federal Arbitration Act does not preempt the state's ability to apply unconscionability analysis to arbitration agreements, as such analysis is a general contract defense that applies equally to all contracts, not just arbitration agreements. The court also determined that the unconscionable parts of the agreement could not be severed to enforce the remainder, as the one-sided terms were central to the agreement's purpose (paras 1-42).