Jupiter Medical Center, Inc. v. Visiting Nurse Association of Florida, Inc. (U.S. Supreme Court)
Jupiter Medical Center (a community hospital) and the Visiting Nurses Association (a home-healthcare agency) arbitrated a contract dispute over the sale of patient accounts for home-based care for patients who have been discharged from the hospital. The arbitrators awarded damages to VNA based on the view that VNA had paid not just to buy existing patient accounts but also to receive preferential future patient referrals, which the hospital did not provide. The hospital moved to vacate the arbitral award, arguing that the arbitrators’ decision converted the parties’ contract into a patient-steering and kickback scheme that would violate federal Medicare law. The Florida Supreme Court held that illegality is not a valid basis for vacating an arbitral award under the Federal Arbitration Act. We filed a cert. petition on behalf of the hospital, presenting the question whether, in articulating several specific grounds for vacating an arbitral award in Section 10 of the Federal Arbitration Act, Congress barred courts from vacating arbitral awards on any other ground, including illegality of the underlying contract as construed by the arbitrators.