Judge Wrongly Axed Arbitration Bid Without Oral Argument, NJ Appeals Court Rules
In a case brought by a former executive of East Orange General Hospital involving an arbitration agreement that only one side signed, a New Jersey appeals court has ruled that a judge shouldn't have rejected a request to arbitrate without holding oral argument or giving a statement of reasons.
November 21, 2018 at 03:45 PM
3 minute read
In a case brought by a former executive of East Orange General Hospital involving an arbitration agreement that only one side signed, a New Jersey appeals court has ruled that a judge shouldn't have rejected a request to arbitrate without holding oral argument or giving a statement of reasons.
A three-judge Appellate Division panel in the whistleblower case said a trial judge erred in denying the defendants' motion to compel arbitration before holding oral argument based solely on the fact that the agreement was missing the employer's signature.
“We agree with defendants that oral argument, or the reason for not affording oral argument, must be provided by the court,” said Appellate Division Judges Ellen Koblitz, Heidi Currier and Jessica Mayer in the unpublished, per curiam decision issued Nov. 21.
According to the court, the case was brought by Anita Walsh, who was hired by East Orange General Hospital to be vice president of operations in September 2016.
At the time of her hiring, she signed an agreement providing that any employment disputes would be settled through arbitration. But no hospital officials signed the agreement, the decision said.
The hospital fired Walsh in March 2017, for reasons that Walsh alleges were “pretextual.” She filed a lawsuit claiming she was wrongfully fired in violation of the state's Conscientious Employee Protection Act because of her complaints about management practices.
Even though she had signed the arbitration agreement, she demanded a jury trial. The hospital then filed a motion to compel arbitration.
At a hearing, Walsh claimed that the agreement was not explained to her, that she did not agree to it, and that it was void because the defendants didn't sign it.
Essex County Superior Court Judge Dennis Carey III denied the hospital's request for oral argument in a March 2018 order that included the handwritten note, “plaintiff did not give up right [to] jury trial.”
The hospital appealed, and the appeals court said the motion judge should have allowed the hospital to make its case at oral argument.
“The court wrote one sentence on the order, finding no evidence of a waiver of a jury trial, although such a waiver is set forth clearly in the agreement,” the panel said. “We are thus unclear as to whether the motion court reviewed the proper material.”
There must be, the appeals court said, a “reasoned decision” on the part of the motion judge. “The trial court must provide reasons with its decisions,” the court said.
The panel remanded the case “for reconsideration, with oral argument.”
Walsh retained Arthur Raynes of Morristown's Wiley Malehorn Sirota & Raynes, while the hospital turned to Ivan Novich, of the Newark office of Littler Mendelson.
Neither returned a call seeking comment.
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