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Marmet Health Care Center, Inc. v. Brown

Supreme Court of the United States
565 U.S. 530, 182 L. Ed. 2d 42, 2012 U.S. LEXIS 1076 (2012)
ELI5:

Rule of Law:

Under the Supremacy Clause, the Federal Arbitration Act (FAA) preempts any state law or public policy that prohibits the arbitration of a particular type of claim, rendering such state laws unenforceable.


Facts:

  • In three separate instances, a family member of a patient requiring nursing home care signed an admission agreement on the patient's behalf.
  • The agreements for two of the patients, Clayton Brown and Jeffrey Taylor, contained a clause requiring the arbitration of all disputes except for claims to collect late payments.
  • The agreement for the third patient, Sharon Marchio, also contained a mandatory arbitration clause but without any exceptions.
  • Subsequently, all three patients died while residents at the nursing homes.
  • The families of the deceased patients brought negligence and wrongful death lawsuits against the nursing homes, alleging that the facilities' negligence caused the deaths.

Procedural Posture:

  • The families of Brown, Taylor, and Marchio filed separate negligence and wrongful death lawsuits in West Virginia state trial courts.
  • The trial court dismissed the suits brought by the families of Brown and Taylor, compelling arbitration based on the admission agreements.
  • The Supreme Court of Appeals of West Virginia, the state's highest court, consolidated the three cases on appeal.
  • The Supreme Court of Appeals of West Virginia reversed the trial court, holding that predispute arbitration clauses in nursing home admission agreements are unenforceable as a matter of state public policy and that this policy is not preempted by the FAA.
  • The nursing homes petitioned the U.S. Supreme Court for a writ of certiorari.

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Issue:

Does the Federal Arbitration Act (FAA) preempt a state's public policy that deems all predispute arbitration agreements for personal injury or wrongful death claims against nursing homes unenforceable?


Opinions:

Majority - Per Curiam

Yes, the Federal Arbitration Act (FAA) preempts a state's public policy that categorically prohibits arbitration for a specific type of claim. The FAA establishes a strong federal policy favoring arbitration and its plain text, which makes written arbitration agreements in contracts involving commerce 'valid, irrevocable, and enforceable,' contains no exception for personal-injury or wrongful-death claims. Citing AT&T Mobility LLC v. Concepcion, the Court reiterated that when a state law outright prohibits arbitration of a particular type of claim, the conflicting state rule is displaced by the FAA. West Virginia’s public policy is precisely such a categorical rule, specifically targeting arbitration, and is therefore contrary to the terms of the FAA and preempted by it.



Analysis:

This decision strongly reaffirms the broad preemptive scope of the Federal Arbitration Act and the supremacy of federal law. It serves as a clear directive to state courts that they cannot carve out public policy exceptions to the FAA's mandate, even for claims involving sympathetic plaintiffs or sensitive subject matters like nursing home negligence. The ruling solidifies the principle that any defense to an arbitration agreement, such as unconscionability, must be based on generally applicable contract law, not on rules that specifically target and disfavor arbitration. This precedent significantly curtails states' abilities to regulate or restrict arbitration agreements within their borders.

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