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Erie Insurance Exchange v. Bristol, M.

Citation: Not availableDocket: Erie Insurance Exchange v. Bristol, M. - No. 124 MAP 2016 (Order Amending Order Granting Petition for Allowance of Appeal originally entered December 29, 2016 at 439 MAL 2016)

Court: Supreme Court of Pennsylvania; May 24, 2017; Pennsylvania; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

In the case of Erie Insurance Exchange v. Michael Bristol and RCC, Inc., the Supreme Court of Pennsylvania addresses critical questions concerning the procedural requirements for initiating arbitration under insurance contracts with mandatory arbitration clauses. The legal dispute centers on whether claimants are obligated to file a Complaint or Petition to Compel Arbitration if their claim remains unresolved four years after the accident, and whether such a requirement conflicts with the Arbitration Act of 1927, which necessitates such filings only when an opposing party declines to arbitrate. The procedural history reveals that the Superior Court's decision may have introduced a new rule potentially inconsistent with established precedents and statutory language. The Supreme Court's review focuses on determining the precise moment a cause of action accrues, thereby triggering the statutory period for filing claims. The case has been thoroughly briefed by both parties, negating the need for additional arguments. The Court's decision will clarify the procedural landscape for arbitration in insurance disputes, directly impacting the parties involved and potentially influencing broader jurisprudence in the state. Chief Justice Saylor and several justices concurred with the decision to hear the case, while Justice Wecht dissented.

Legal Issues Addressed

Accrual of Cause of Action in Insurance Arbitration

Application: The court is tasked with determining when the statutory period begins for claims under insurance contracts with mandatory arbitration provisions.

Reasoning: The issue involves when a cause of action accrues, thereby starting the statutory period for claims under insurance contracts with mandatory arbitration provisions.

Consistency with the Arbitration Act of 1927

Application: The court considers whether the requirement to file contradicts the Arbitration Act of 1927, which mandates filings only when the opposing party refuses arbitration.

Reasoning: Whether this requirement contradicts the Arbitration Act of 1927, which states that such filings are necessary only when an opposing party refuses to arbitrate.

Filing Requirements for Arbitration in Insurance Claims

Application: The court examines whether claimants must file a Complaint or Petition to Compel Arbitration if the claim remains unresolved four years post-accident.

Reasoning: Whether a claimant must file a Complaint or a Petition to Compel Arbitration if their claim does not resolve within four years of the accident date.