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Coventry Health Care of Florida v. Crosswinds Rehab
Citation: 259 So. 3d 306Docket: 18-1342
Court: District Court of Appeal of Florida; November 27, 2018; Florida; State Appellate Court
Original Court Document: View Document
Coventry Health Care of Florida, Inc. appeals a circuit court's order denying its motion to compel arbitration in a putative class action brought against it by 206 Golden, LLC. The court affirmed the denial, establishing that 206 Golden is not the entity that entered into a 2012 participating provider agreement with Coventry, which was signed by a previous operator of the skilled nursing facility known as "The Crossroads." This agreement included a binding arbitration provision but explicitly excluded long-term care services. Coventry argued that 206 Golden's submission of claims and receipt of payments since 2014 indicated the agreement's continued applicability. However, 206 Golden countered that it neither signed nor agreed to the prior agreement's terms and that any claims submitted were solely for long-term care services, which are excluded under the agreement. The court found the key issue to be that no valid arbitration agreement existed between the parties, referencing the precedent set in Careplus Health Plans, Inc. v. Interamerican Medical Center Group, LLC, where the court determined that the trial court, not an arbitrator, should decide the applicability of an arbitration provision when the agreement was not signed by the entity against whom enforcement was sought. The agreement’s language did not extend to successors of the provider, and there was no evidence to support an implied assumption of the agreement by 206 Golden or estoppel against it. The court concluded that the lack of a valid arbitration agreement warranted the affirmation of the trial court's order denying Coventry's motion to compel arbitration.