On March 5, 2025, Florida’s Fourth District Court of Appeal ruled in United Healthcare of Florida, Inc. v. North Broward Hospital District d/b/a Broward Health, reversing a trial court’s denial of arbitration. This decision clarifies who decides if a dispute is arbitrable when contracts specify, affecting litigants in contract disputes.
The Case
United Healthcare (“United”) and Broward Health signed agreements in 2012-2014 for hospital and professional services, with clauses mandating good-faith dispute resolution, including arbitrability questions, and binding arbitration under AAA rules if unresolved after 60 days. In 2022, after terminations and reinstatements, Broward Health sued United for underpayment during an “out-of-network” period. United moved to compel arbitration; Broward Health argued the claims predated reinstatement. The trial court denied arbitration, but the Fourth District reversed.
The Holding: Arbitrators Decide Arbitrability
The appellate court examined who decides arbitrability—judge or arbitrator. United highlighted the agreements’ delegation of “all questions of arbitrability” to arbitration, reinforced by AAA rules. Broward Health cited a “Court Determination” clause, but the Fourth District found “clear and unmistakable” intent favoring arbitrators, prioritizing specific arbitration terms over general court provisions. The case was remanded to an arbitration panel to determine arbitrability.
Impact on Litigants
This ruling significantly shapes how contract disputes unfold for litigants. When contracts clearly delegate arbitrability to arbitrators, especially through AAA rules, courts are likely to step aside, limiting litigants’ ability to keep cases in court and favoring faster, private resolution. It reinforces that specific arbitration clauses outweigh vaguer court-related terms, highlighting the need for precise drafting in agreements. The decision also means arbitrators, not judges, may resolve disputes over timing or scope if the contract so intends, regardless of when claims arose. As a result, litigants must evaluate arbitration provisions early, since challenging them in court could prove futile, shifting strategic planning toward arbitration.
Looking Ahead
The decision underscores judicial deference to arbitration when contracts are clear. For litigants, it’s a cue to scrutinize dispute clauses—arbitration can dictate a case’s path, proving intent in the contract reigns supreme.
Contact Rosenthal Law Group to assist you with your arbitration matters. Mr. Rosenthal is a certified arbitrator and he and his firm have extensive experience litigating matters in arbitration. Call us today at (954) 384-9200 or www.rosenthalcounsel.com.