Madison A. West v. Cigna Health and Life Insurance Company, d/b/a Cigna Healthcare, and eviCore Healthcare MSI, LLC

Summary

The United States District Court for the Middle District of Tennessee grants defendants’ motion to compel arbitration and dismisses without prejudice Madison A. West’s claims concerning the denial of inpatient postoperative care. The court holds that West assented to the health insurance policy containing a binding arbitration provision and that the incorporated arbitration rules clearly and unmistakably delegate arbitrability questions to the arbitrator. The court declines to stay the proceedings because dismissal pending arbitration is appropriate under its precedent.

Holdings

1. An unsigned insurance policy may establish an enforceable arbitration agreement when the parties' conduct objectively demonstrates acceptance of the policy's terms. West's reliance on the policy and concessions regarding its validity demonstrated assent to all of its terms, including the arbitration provision.
2. West's claims arose within the scope of the policy's arbitration provision, and no exemption or congressional designation of nonarbitrability was shown.
3. The arbitration agreement clearly and unmistakably delegated questions of arbitrability to the arbitrator by incorporating American Health Lawyers Association rules granting the arbitrator authority to determine jurisdiction and arbitrability.
4. The court dismissed the action without prejudice after compelling arbitration because no issues remained for judicial consideration until arbitration was completed.

Questions Presented

1. Whether the parties entered into an enforceable arbitration agreement despite the absence of West's signature and her alleged lack of notice of the arbitration provision.
2. Whether West's claims fell within the scope of the policy's arbitration provision.
3. Whether the incorporated American Health Lawyers Association arbitration rules clearly and unmistakably delegated questions of arbitrability to the arbitrator.
4. Whether eviCore, a nonsignatory to the policy, could enforce the arbitration provision.
5. Whether dismissal without prejudice, rather than a stay, was appropriate after compelling arbitration.

Disposition

dismissed