IHS Acquisition No. 131, Inc. d/b/a Horizon Healthcare Center at El Paso v. Martha Iturralde

Summary

The Eighth District Court of Appeals of Texas held that an employee’s signed arbitration agreement clearly and unmistakably delegated gateway issues concerning validity and enforceability to the arbitrator. The court also concluded that the reference to a different affiliated employer was a misnomer that did not make the agreement unenforceable. It reversed the denial of the motion to compel arbitration and remanded for orders compelling arbitration.

Holdings

1. The Mutual Arbitration Agreement clearly and unmistakably delegated issues concerning the validity and enforceability of the agreement to the arbitrator; therefore, Iturralde's challenge that the agreement was illusory or lacked consideration had to be submitted to arbitration rather than decided by the court.
2. The misnomer identifying the employer as IHS Acquisition No. 174 did not render the arbitration agreement unenforceable because the signed agreement, the employment relationship, and the surrounding circumstances demonstrated the parties' intent to arbitrate disputes between Iturralde and her actual employer, IHS Acquisition No. 131.
3. The trial court erred in refusing to compel arbitration because IHS established the existence of an enforceable arbitration agreement covering the dispute, and Iturralde did not prove an affirmative defense to arbitration.

Questions Presented

1. Whether the Mutual Arbitration Agreement clearly and unmistakably delegated gateway issues concerning validity, enforceability, formation, and arbitrability to the arbitrator.
2. Whether the agreement was unenforceable because it identified IHS Acquisition No. 174 rather than IHS Acquisition No. 131 as the employer.
3. Whether the trial court erred by refusing to compel arbitration when Iturralde did not establish an affirmative defense to enforcement.

Disposition

reversed_and_remanded