Affordable Care v. McIntyre

CourtCourt of Appeals for the Fifth Circuit
DecidedMay 24, 2023
Docket22-60245
StatusUnpublished

This text of Affordable Care v. McIntyre (Affordable Care v. McIntyre) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Affordable Care v. McIntyre, (5th Cir. 2023).

Opinion

Case: 22-60245 Document: 00516762289 Page: 1 Date Filed: 05/24/2023

United States Court of Appeals for the Fifth Circuit United States Court of Appeals Fifth Circuit

____________ FILED May 24, 2023 No. 22-60245 Lyle W. Cayce ____________ Clerk

Affordable Care, L.L.C.,

Plaintiff—Appellant,

versus

Raeline K. McIntyre, DMD; Raeline K. McIntyre, DMD, P.C.,

Defendants—Appellees. ______________________________

Appeal from the United States District Court for the Southern District of Mississippi USDC No. 1:21-CV-85 ______________________________

Before Elrod and Haynes, Circuit Judges. † Per Curiam: * Affordable Care lost at arbitration. It now seeks vacatur of the resulting arbitration award because the arbitrator and an attorney for the other side both have connections to Duke University School of Law.

_____________________ † Judge Willett was a member of the panel that heard oral argument. He has since recused and has not participated in this decision. This case is being decided by a quorum. 28 U.S.C. § 46(d). * This opinion is not designated for publication. See 5th Cir. R. 47.5. Case: 22-60245 Document: 00516762289 Page: 2 Date Filed: 05/24/2023

No. 22-60245

The district court correctly determined that these connections do not create a conflict. We therefore AFFIRM the district court’s denial of relief. I Charles Holton was assigned to arbitrate a contract dispute between Affordable Care L.L.C., which provides non-clinical business services to affiliated dentists, and Dr. Raeline McIntyre and her dental practice. After Holton completed the ordinary conflict disclosure form, Dr. McIntyre added Paul Sun to her legal team. Holton made the following supplemental disclosure the day after Sun entered his appearance: I would disclose that I know Mr. Sun and probably have had one or more cases with him or against him during my career, but nothing in the last 10 years. I do not believe that I have seen or communicated with him in over 10 years. His involvement would not affect my judgment in the case. 1 The American Arbitration Association requested objections to the disclosure, but none were made. The arbitration process then proceeded to its conclusion with Holton ultimately rejecting each of Affordable’s claims and awarding attorney fees to Dr. McIntyre.

Affordable subsequently moved to vacate the award in the United States District Court for the Southern District of Mississippi, citing the Federal Arbitration Act’s four statutory grounds for relief. It also sought discovery related to Holton’s alleged bias and partiality.

In support of its requests, Affordable submitted screenshots taken from the webpages of Duke’s law school and Sun’s firm, as well as a local news article. With this publicly available information, Affordable was able to

_____________________ 1 Thus, this is not a case involving a complete lack of disclosure.

2 Case: 22-60245 Document: 00516762289 Page: 3 Date Filed: 05/24/2023

ascertain that both Holton and Sun worked at Duke University School of Law: Holton as a full-time faculty member and Sun as a “2021 Wintersession” adjunct. Affordable also determined that Holton served as the director of Duke’s Civil Justice Clinic, which partners with a local legal aid service that Sun’s firm also partners with, and that Sun has provided legal representation to Duke University. 2 The district court reviewed this evidence and concluded that Affordable failed to establish grounds for vacatur under the FAA and that discovery was not warranted. It therefore denied Affordable’s motions and confirmed the award. Affordable now appeals. II Affordable maintains that Holton’s arbitration award must be vacated under the FAA due to “evident partiality or corruption in the arbitrator[].” 9 U.S.C. § 10(a)(2). We disagree. The standard for establishing evident partiality is “stern.” OOGC America, L.L.C. v. Chesapeake Expl., L.L.C., 975 F.3d 449, 453 (5th Cir. 2020) (quoting Positive Software Sols., Inc. v. New Century Mortg. Corp., 476 F.3d 278, 281 (5th Cir. 2007) (en banc)). The challenger must show “a concrete, not speculative impression of bias” that “stem[s] from a significant,” not trivial, “compromising connection.” Id. (citation and quotation marks omitted). “[T]he party challenging the award ‘must produce specific facts from which a reasonable person would have to

_____________________ 2 Affordable also asserted that “Holton represented Duke University in many lawsuits from 1983 through 2005” and that “Sun and [his firm] took over representation of Duke University following Holton’s long representation.” But, as the district court noted, Affordable has not produced any evidence of Holton’s “long representation” of Duke. Nor did it provide any evidence to substantiate its assertion that Holton had handed litigation over to Sun or his firm.

3 Case: 22-60245 Document: 00516762289 Page: 4 Date Filed: 05/24/2023

conclude that the arbitrator was partial to’ its opponent.” Id. (quoting Cooper v. WestEnd Cap. Mgmt., L.L.C., 832 F.3d 534, 545 (5th Cir. 2016)). The connections derived from Affordable’s internet research do not establish a conflict of the sort contemplated by the FAA. To the contrary, they are quintessential examples of the kind of “trivial past association” our precedents have deemed insufficient to warrant “the extreme remedy of vacatur.” Positive Software, 476 F.3d at 279. Indeed, once separated from Affordable’s inflammatory characterizations, the evidence in the record reflects the kind of professional intersections that one might expect to find between any two attorneys working in the same geographical location. Affordable has shown that both Holton and Sun served on the faculty of Duke’s law school—one as an adjunct for the winter term and one as a full- time faculty member—and that Holton and Sun were both part of organizations that served the same legal aid non-profit. This cannot, standing alone, cast Holton’s impartiality into doubt. It does not follow that Sun and Holton had any kind of personal, professional, or financial relationship. We also agree with the district court that Affordable’s bald assertion that Sun and Holton shared an attorney-client relationship through Holton’s employment with Duke University is unsupported by the facts and the law. This would be a different case if Affordable had offered evidence that Holton and Sun worked closely together. But we cannot, on this record, conclude that Holton and Sun were even aware of their shared Duke connection. We have upheld arbitration awards in the face of much stronger indicia of a potential conflict. See e.g., Positive Software, 476 F.3d at 283–84 (declining to vacate award where prevailing party’s attorney had previously litigated with the arbitrator); Cooper, 832 F.3d at 540 (declining to vacate award based on an undisclosed relationship between the opposing party and

4 Case: 22-60245 Document: 00516762289 Page: 5 Date Filed: 05/24/2023

another arbitrator who worked for the same arbitral organization that the presiding arbitrator belonged to); OOGC, 975 F.3d at 451 (declining to vacate award despite allegations that the arbitrator had a financial incentive to rule a certain way).

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Positive Software v. New Century Mortgage
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Bluebook (online)
Affordable Care v. McIntyre, Counsel Stack Legal Research, https://law.counselstack.com/opinion/affordable-care-v-mcintyre-ca5-2023.