Hayes v. Oakridge Home

Summary

The Supreme Court of Ohio held that a nursing-home arbitration agreement voluntarily executed upon admission and not required as a condition of admission was not procedurally unconscionable solely because of the resident’s age. The court also held that waivers of the right to trial, punitive damages, and attorney fees were not substantively unconscionable, and it reversed the appellate court and reinstated the trial court’s order compelling arbitration. The opinion addresses contractual consideration and Ohio’s policy favoring arbitration.

Holdings

1. A voluntary arbitration agreement executed by a nursing-home resident upon admission and not as a precondition to admission is not rendered procedurally unconscionable solely by virtue of the resident's age.
2. An arbitration agreement voluntarily executed by a nursing-home resident and not as a precondition to admission that waives the rights to trial, punitive damages, and attorney fees is not substantively unconscionable.
3. The arbitration agreement was supported by sufficient consideration even though Hayes waived her right to trial.
4. An arbitration agreement is enforceable unless a legal or equitable ground for revocation of a contract, including unconscionability, is established; a court may stay litigation involving an arbitrable issue.

Questions Presented

1. Whether a nursing-home resident's age, standing alone, renders a voluntarily executed arbitration agreement procedurally unconscionable.
2. Whether an arbitration agreement voluntarily executed by a nursing-home resident that waives the rights to trial, punitive damages, and attorney fees is substantively unconscionable.
3. Whether the arbitration agreement lacked consideration because Hayes waived her right to trial without receiving consideration in return.

Disposition

reversed