Court Emphasizes that Questions of Substantive Arbitrability are Reserved for the Arbitrator
Carroll v. Castellanos
In
Carroll v.
Castellanos
, the arbitration provision at issue was contained in a “Physician Employment Contract” executed by Dr. Castellanos and the University of Alabama Health Services Foundation, P.C. (“UAHSF”). The arbitration provision provided that any claim or controversy arising out of or relating to the employment contract should be settled by arbitration in Birmingham, Alabama. During his employment at UAB Medical Center, Dr. Castellanos alleged that Dr. Carroll (the interim chairman of the ENT Department at UAB Medical Center), Dr. Rue, and Dr. Heudebert mistreated him and conspired to make him want to leave his employment. In his Complaint, Dr. Castellanos asserted claims of intentional infliction of severe mental anguish – outrageous conduct, defamation, and invasion of privacy – false light specifically against Dr. Carroll. He also asserted a claim of intentional interference with contractual and business relations against all the individual defendants.
The individual defendants, including Dr. Carroll, filed a motion to compel arbitration regarding the claims asserted against them. The circuit court entered an order denying arbitration of Dr. Castellanos’s claims against the individual defendants. In its refusal to compel arbitration of the claims against the individual defendants, the circuit court reasoned that the employment contract did not include an arbitration clause applicable to the individual defendants since they were not signatories to the employment contract. The individual defendants appealed this decision to the Alabama Supreme Court.
On appeal, the threshold issue before the Alabama Supreme Court was whether a circuit court has the liberty to decide questions of substantive arbitrability. The individual defendants noted that it could not be ignored regarding the fact that the employment contract contained an arbitration provision which reserved questions of substantive arbitrability to the arbitrator. However, Dr. Castellanos argued that the arbitration provision should not be enforced because there was no legal or logical nexus to the claims asserted against the individual defendants and the employment contract. Although Dr. Castellanos may have been correct that his claims against the individual defendants did not fall within the scope of the arbitration provision, the Court agreed with the defendants and emphasized that the circuit court did not have the liberty to make determinations of substantive arbitrability. Thus, the Court reversed the circuit court’s order.
