Peak Billing v. Mountain Sleep Diagnostics

2020 COA 155
CourtColorado Court of Appeals
DecidedNovember 5, 2020
Docket19CA0608
StatusPublished

This text of 2020 COA 155 (Peak Billing v. Mountain Sleep Diagnostics) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Peak Billing v. Mountain Sleep Diagnostics, 2020 COA 155 (Colo. Ct. App. 2020).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY November 5, 2020

2020COA155

No. 19CA0608, Peak Billing v. Mountain Sleep Diagnostics —

ADR – Arbitration – Colorado Uniform Arbitration Act –

Vacating Award

A division of the court of appeals considers when an

arbitration award should be vacated because it was procured by

fraud, corruption, or undue means, per section 13–22–223(1)(a),

C.R.S. 2020, of the Colorado Revised Uniform Arbitration Act. The

division adopts a three-part test widely used in federal and other

state courts to determine when such an award should be vacated

and holds that in this case the award should stand. COLORADO COURT OF APPEALS 2020COA155

Court of Appeals No. 19CA0608 Adams County District Court No. 18CV30091 Honorable Edward C. Moss, Judge

Tara Price, d/b/a Peak Billing,

Plaintiff-Appellee,

v.

Mountain Sleep Diagnostics, Inc.,

Defendant-Appellant.

JUDGMENT AFFIRMED

Division III Opinion by JUDGE GROVE Furman and Berger, JJ., concur

Announced November 5, 2020

Messner Reeves LLP, Kendra Beckwith, Darren D. Alberti, Denver, Colorado, for Plaintiff-Appellee

Fairfield and Woods, P.C., Cecil E. Morris Jr., Denver, Colorado, for Defendant- Appellant ¶1 Mountain Sleep Diagnostics, Inc. (MSD), appeals the trial

court’s judgment confirming an arbitration award against it and in

favor of Tara Price doing business as Peak Billing (Price). Applying

section 13–22–223(1)(a), C.R.S. 2020, of the Colorado Revised

Uniform Arbitration Act (CRUAA), which allows a court to vacate an

arbitration award procured by fraud, corruption, or undue means,

we adopt the test developed by federal courts under an analogous

provision of the Federal Arbitration Act (FAA) and conclude that

MSD’s motion failed to make an adequate showing that MSD was

entitled to relief. Because the district court correctly denied MSD’s

motion without holding a hearing, we affirm its judgment.

I. Background

¶2 Price contracted with MSD to provide billing services for MSD

and its patients. The contract automatically renewed every year

unless one party notified the other of its intent to terminate at least

ninety days before the renewal date. Disputes under the contract

— including any involving inadequate notice of the contract’s

termination — were subject to binding arbitration. The arbitration

clause also provided that the prevailing party in any arbitrated

dispute was entitled to an award of attorney fees.

1 ¶3 After MSD terminated the contract less than ninety days

before the renewal date, Price, asserting that the untimely notice

was a breach, filed a motion to compel arbitration in the district

court. The court granted the motion, and the parties reached a

stipulation and agreement to arbitrate.

¶4 After a two-day arbitration hearing, the arbitrator awarded

Price $124,224 for MSD’s breach of the contract plus $24,600 in

attorney fees. Price then filed a motion in district court to confirm

the award. MSD moved to vacate the award, alleging that, while

performing billing services for MSD, Price had committed fraud by

misappropriating more than $60,000 in payments meant for MSD.

The trial court issued an order denying MSD’s motion to vacate and

granting Price’s motion to confirm.

¶5 MSD now appeals that order, arguing that the arbitrator’s

award should be vacated because discoveries it made after the

arbitration was complete establish by clear and convincing evidence

that Price procured the arbitration award through fraud.1

1MSD first argues that the trial court erred by denying its motion to vacate as untimely. But the trial court denied MSD’s motion on the merits; it did not question its timeliness. We therefore do not address this argument.

2 II. Analysis

A. Standard of Review

¶6 We review de novo a district court’s legal conclusions on a

motion to confirm or vacate an arbitration award. Pacitto v.

Prignano, 2017 COA 101, ¶ 7. In the absence of statutory grounds

to vacate an arbitration award, we must affirm the award without

reviewing its merits. PFW, Inc. v. Residences at Little Nell Dev., LLC,

2012 COA 137, ¶ 37.

B. Applicable Law

¶7 Under the CRUAA, courts can reject arbitration awards “only

in limited circumstances.” Barrett v. Inv. Mgmt. Consultants, Ltd.,

190 P.3d 800, 802 (Colo. App. 2008). These limited circumstances,

listed in section 13–22–223(1), involve “specific instances of

outrageous [arbitral] conduct” and “egregious departures from the

parties’ agreed-upon arbitration.” Treadwell v. Vill. Homes of Colo.,

Inc., 222 P.3d 398, 401 (Colo. App. 2009) (quoting Hall St. Assocs.,

L.L.C. v. Mattel, Inc., 552 U.S. 576, 586 (2008)).

¶8 Though the merits of an arbitration award are generally

unreviewable, a court “shall” vacate an arbitration award if, as

relevant here, it was “procured by corruption, fraud, or other undue

3 means.” § 13–22–223(1)(a). What exactly constitutes corruption,

fraud, or undue means, however, is largely unsettled in Colorado.

C. MSD’s Motion to Vacate

¶9 Affidavits attached to MSD’s motion to vacate the arbitration

award alleged that after the arbitration was complete, MSD’s Chief

Operating Officer discovered suspicious activity in MSD’s billing

software system, and that further examination of that system

revealed more than $60,000 in misappropriated payments. MSD

argues that by “concealing and failing to disclose that she had been

misappropriating funds” — and “by testifying falsely on several

related issues” — Price procured the arbitration award by fraud.2

¶ 10 The district court did not decide whether Price in fact

misappropriated the funds in question. Instead, it ruled that MSD’s

motion failed to establish that MSD could not have discovered the

alleged misappropriation sooner. The undisputed facts showed that

MSD had “locked out” Price’s access to the billing software system

on the same day that it terminated the contract, and that a full

fourteen months elapsed between that termination and the date of

2MSD did not allege any impropriety on the part of the arbitrator or corruption in the arbitration process.

4 the arbitration award. Yet, despite having ample time to review its

books, MSD never raised the issue in the arbitration even though it

had asserted the defense of unclean hands. Because “[w]rongful

conduct by [Price] was part of [MSD’s] case,” and because

“[i]nformation concerning [Price’s] wrongful conduct was in [MSD’s]

possession prior to the arbitration hearing,” the district court ruled

that it was too late for MSD to assert Price’s alleged

misappropriation as a basis for vacating the award.

D.

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2020 COA 155, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peak-billing-v-mountain-sleep-diagnostics-coloctapp-2020.