Alabama Psychiatric Services, P.C. v. Lazenby et al.Annotate this Case
Several former employees of Alabama Psychiatric Services, P.C. ("APS"), filed a putative class action against APS and Managed Health Care Administration, Inc. ("MHCA"), an affiliate of APS, alleging APS had not paid the former employees for unused vacation time after they lost their jobs when APS went out of business. APS and MHCA moved the circuit court to compel arbitration pursuant to arbitration agreements the plaintiffs had entered into with APS. APS and MHCA asked the circuit court to determine, as a threshold question, whether class arbitration was available in this case because the arbitration agreements at issue did not expressly mention class arbitration. The circuit court issued an order granting the motion to compel arbitration, declining to decide whether class arbitration was available, concluding that that issue was to be decided by the arbitrator. The case proceeded to arbitration. The arbitrator issued a clause-construction award ("the award"), concluding that the relevant arbitration agreements authorized class arbitration in this case. APS and MHCA sought review of the award by the circuit court, which denied the motion to vacate the arbitrator’s award. The parties then applied to the Alabama Supreme Court, which noted multiple procedural irregularities in the circuit court’s order. The issue of whether the circuit court erred regarding its order not vacating the arbitration agreement was not properly before the Supreme Court. APS and MHCA attempted to challenge that part of the order compelling arbitration in which the circuit court declined to decide the availability of class arbitration. However, to properly challenge that aspect of the earlier order, APS and MHCA should have appealed the order. APS and MHCA also argued the circuit court erred by failing to apply a de novo standard of review of the arbitrator’s award. The Supreme Court determined the circuit court did not err in this respect. The Supreme Court therefore affirmed the circuit court in denying the motion to vacate the arbitrator’s award, and dismissed appeal 1171150 as redundant.