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

• Plaintiff Nina Strausberg signed an arbitration agreement as a condition for her admission to Arbor Brook Healthcare nursing home. After receiving care, she sued Arbor Brook and several other defendants for alleged negligent care. Defendants moved to compel arbitration based on the signed agreement. Plaintiff contended the arbitration agreement was unconscionable (paras 1, 4-7).

Procedural History

• Strausberg v. Laurel Healthcare Providers, LLC, 2012-NMCA-006: The Court of Appeals reversed the district court's decision, holding that the burden to prove an arbitration agreement is not unconscionable lies with the nursing home when the agreement is signed as a condition for admission (para 2).
• District Court: Found Plaintiff had failed to prove unconscionability and granted Defendants’ motion to compel arbitration (para 1).

Parties' Submissions

• Plaintiff: Argued the arbitration agreement was both substantively and procedurally unconscionable due to its terms and the circumstances of its formation. Claimed the agreement was unfair, lacked consideration and mutuality of obligation, and that the representative lacked authority to enter the contract on behalf of Defendants (para 7).
• Defendants: Moved to dismiss Plaintiff’s case and to compel arbitration, arguing all of Plaintiff’s claims were covered by the arbitration agreement (para 7).

Legal Issues

• Whether the party asserting an arbitration agreement is unconscionable bears the burden of proof (para 3).
• Whether the Court of Appeals erred in holding that the nursing home has the burden of proving an arbitration agreement is not unconscionable when signed as a condition for admission (para 3).

Disposition

• The Supreme Court of New Mexico reversed the Court of Appeals' decision and remanded the case for further proceedings to determine whether the district court erred by granting Defendants’ motion to compel arbitration (para 59).

Reasons

• The Supreme Court held that the Plaintiff bears the burden to prove that the arbitration agreement is unconscionable because unconscionability is an affirmative defense to contract enforcement. This decision is based on settled principles of New Mexico law, where the party asserting an affirmative defense has the burden of proof. The Court also found that the Court of Appeals’ holding is preempted by federal law because it treats nursing home arbitration agreements differently than other contracts, which is contrary to the Federal Arbitration Act's mandate that arbitration agreements must be treated the same as other contracts. The Court declined to consider the merits of Plaintiff’s unconscionability defense, leaving that issue to be addressed by the Court of Appeals (paras 3, 36-58).