McGuffey Health and Rehabilitation Center v. Gibson

Summary

The Alabama Supreme Court held that an admission agreement between a nursing home and a resident substantially affected interstate commerce because Medicare funds and care-related materials moved across state lines. The court therefore reversed the trial court's refusal to compel arbitration of the resident's medical-malpractice claim and remanded for further proceedings.

Holdings

1. Medicare funds moving across state lines may be considered in determining whether a nursing-home admission agreement substantially affects interstate commerce. Because two-thirds of McGuffey's payments for Gibson's care came from out of state and McGuffey purchased materials from out-of-state vendors, the admission agreement substantially affected interstate commerce and the arbitration provision was enforceable.

Questions Presented

1. Whether the nursing-home admission agreement evidenced a transaction substantially affecting interstate commerce so that the Federal Arbitration Act required arbitration of Gibson's medical-malpractice action.

Disposition

reversed_and_remanded