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

• Diane Wilkins was admitted to Rio Rancho Center, a skilled nursing and therapy rehabilitation center, where she stayed from February 18, 2018, to March 26, 2018. Upon her first admission, her daughter, acting on her behalf, signed Voluntary Binding Arbitration Agreements as part of the admission packets. These agreements were intended to arbitrate any disputes arising from Wilkins's stay at the center. Despite the agreements stating they were voluntary and not a precondition for receiving services, Wilkins died on March 27, 2018, due to septic shock and respiratory failure. Subsequently, Andras Szanthos, as personal representative of Wilkins's estate, filed a complaint against the center and associated entities, alleging wrongful death, negligence, and unfair trade practices (paras 2-5).

Procedural History

• District Court of Santa Fe County: Denied Defendants' motion to compel arbitration, following the opinion in Peavy v. Skilled Healthcare Group, and ordered discovery and evidentiary briefing on the issue of substantive unconscionability (paras 6-9).

Parties' Submissions

• Plaintiff: Argued that the arbitration agreements lacked mutuality of obligation due to a carve-out for small claims, rendering them substantively unconscionable and unenforceable. Asserted that the district court had jurisdiction to decide the enforceability issue (para 5).
• Defendants: Contended that the arbitration agreements' delegation clause mandated that questions of enforceability, including unconscionability, be decided by arbitration. They sought to compel arbitration based on the agreements signed on behalf of Ms. Wilkins (para 5).

Legal Issues

• Whether the arbitration agreements signed on behalf of Diane Wilkins for her admission to Rio Rancho Center were substantively unconscionable and thus unenforceable.
• Whether the district court had the authority to decide on the enforceability of the arbitration agreements, including the issue of substantive unconscionability.

Disposition

• The Court of Appeals reversed the district court's decision and remanded with directions to refer the case to arbitration (para 19).

Reasons

• The Court of Appeals, with Judge Pro Tem Bruce D. Black writing and Judges J. Miles Hanisee and Katherine A. Wray concurring, based its decision on the principle that parties agreeing to a nonjudicial forum for dispute resolution should be held to that agreement unless it is voluntary and not substantively or procedurally unconscionable. The court found that the plaintiff's challenge to the arbitration provision as a whole, without specifically challenging the delegation clause, was insufficient. Citing Evangelical Lutheran Good Samaritan Society v. Moreno and Green v. St. Theresa Healthcare and Rehabilitation Center, LLC, the court noted that challenges to the contract as a whole are not relevant to determining the enforceability of the arbitration agreement. The court concluded that the district court erred in denying arbitration because the delegation clause clearly delegated threshold matters of arbitrability to arbitration, and the plaintiff failed to issue a specific challenge to the delegation provision (paras 10-18).