Sandoval-Ryan v. Oleander Holdings LLC

Summary

The California Court of Appeal affirmed an order denying defendants’ petition to compel arbitration in a nursing-facility care dispute. The court held that the arbitration agreements did not clearly and unmistakably delegate threshold questions concerning the validity or enforceability of the arbitration agreements to an arbitrator. The court therefore declined to reach the trial court’s alternative ruling under California Code of Civil Procedure section 1281.2, subdivision (c).

Holdings

1. The arbitration agreements did not clearly and unmistakably delegate threshold questions concerning the validity, interpretation, or enforceability of the arbitration agreements to the arbitrator. The phrase concerning the validity, interpretation, construction, performance, and enforcement of the admission agreement referred to the admission agreement, not the separate arbitration agreements.
2. The court did not reach the trial court's alternative ruling under Code of Civil Procedure section 1281.2, subdivision (c), because defendants' challenge to the trial court's threshold arbitrability determination failed.

Questions Presented

1. Whether the arbitration agreements clearly and unmistakably delegated threshold questions concerning the validity and enforceability of the arbitration agreements to the arbitrator rather than the court.
2. Whether the Court of Appeal should reach the trial court's alternative ruling denying arbitration under Code of Civil Procedure section 1281.2, subdivision (c).

Disposition

affirmed