An Introduction to The Use Of Alternative Dispute Resolution to Resolve Insurance Disputes

 

Jay E. Grenig*

 

I.

Introduction

 

            Alternative dispute resolution describes the techniques or procedures for resolving disputes short of trial in the public courts.  Alternatives to civil litigation are not a new phenomenon.[1]  However, in recent years the interest in alternative dispute resolution has increased.[2]  Non-judicial procedures may be superior in a variety of disputes.  They may be less expensive, faster, less intimidating, more sensitive to the disputants’ concerns, and more responsive to the underlying problems.

            The first section of this article provides an introduction to alternative dispute resolution.  The second section discusses the Federal Arbitration Act[3] and the McCarran-Ferguson Act.[4]  The third section examines the use of various alternative dispute resolution processes in addressing different types of insurance situations.

 

II.

Alternative Dispute Resolution

 

            A. Generally

            There are a number of voluntary alternative dispute resolution methods available to facilitate the settlement of disputes or to adjudicate disputes if settlement cannot be reached.  These methods can be used separately or in combination, and their components can be modified and mixed to suit the circumstances of the particular case.

 

      B. Negotiation

            Negotiation normally should be considered the first step in attempting to resolve any dispute.[5]  It is probably the most frequently used method of dispute resolution.  Negotiation implies joint responsibility and authority for making certain decisions.  Parties to a dispute may utilize negotiation to solve their problems and disputes directly as between themselves, without the involvement of a third party.

            The negotiation process is voluntary and non-binding.  In negotiation, two or more disputing parties meet together in good faith to identify and discuss the issues at hand, present facts and supporting data, arrive at mutual solutions, and abide by the outcome.  Negotiation continues as long as the parties are willing to exchange views on settlement.

 

      C. Conciliation

            Conciliation is the process in which a third party brings the disputing parties together so that the disputing parties can begin to discuss the issues.  It involves the adjustment and settlement of a dispute in a friendly, non-antagonistic manner.  Conciliation may be used in the courts before trial, with a view towards avoiding trial, and in labor disputes prior to arbitration.

            Conciliation may be a particularly good choice when emotions are running high, or when ongoing relationships are involved and the parties’ inability or unwillingness to communicate is a major barrier to resolution.  Conciliation also may be inappropriate where one party has a clear legal entitlement or where the parties have unequal bargaining power or sophistication.

            The term “conciliation” is frequently used interchangeably with “mediation.”[6]  However, conciliation generally refers to a process less structured than mediation.  In some forms of conciliation, a conciliator does not take active part in the process or settlement discussions, while a mediator may actively promote a mutually acceptable settlement.  The conciliator’s primary role is to reduce the parties’ inflammatory rhetoric and tension, open channels of communication, and arrange for formal negotiations.

            Unlike a mediator, a conciliator sometimes is called upon to make non-binding recommendations or findings that often concern the factual or legal issues in dispute.  The conciliator also may recommend an appropriate resolution under the circumstances.[7]  The finding or recommendation is made to the parties jointly by the conciliator.

 

      D. Mediation

            Mediation introduces the assistance of a neutral third party -- the “mediator” -- in attempting to resolve the dispute.[8]  The mediator’s function is to assist the parties in their negotiations by helping the parties to define the issues, to overcome barriers to communication, and to explore alternative methods of resolving their dispute.[9]  Mediation enhances the parties’ ability to communicate with each other. The mediation process is voluntary; either party can reject further participation by the mediator at any time in the process.  The mediator has no authority to impose a settlement and does not render a binding decision.  A mediator can clarify the parties’ expectations by focusing their needs and interests, attempting to diffuse hostilities, and reducing the adverse impact of emotions.  The parties retain complete control over the process and make their own decisions about what solutions will work for them.

            The mediator usually deals directly with the parties or their representatives.  The mediator endeavors to ensure that each party is evaluating his or her position realistically.  A mediator helps the parties appreciate the difference between the best alternative to a negotiated agreement and the worst alternative to a negotiated agreement.

            A mediator can facilitate the resolution of a dispute by suggesting non-monetary benefits that cost the party providing the benefit less than the value of the benefit to the other.  A mediator also can help parties overcome perceptive differences.  By communicating directly with those persons having settlement authority, a mediator can reduce the risk of a conflict of interest between a party and its negotiating representatives.  To be most successful in this regard, a mediator should strive to appear fair and impartial.  Furthermore, the mediator should analyze the disputed issues and prioritize them in order to facilitate resolution of the dispute.

            Some mediators favor party-generated settlement options and do not suggest settlement terms.  They see themselves primarily as facilitators, digging deep into the interests and feelings underlying the surface dispute.[10]  Other mediators will propose settlement options and attempt to persuade the parties to make concessions.  In some cases, the mediator may be asked to offer an assessment of the probable outcome of the case in order to facilitate the parties’ more realistic evaluation of their respective positions.

            In evaluative mediation, the mediator decides what the case is worth and advises how it should be settled.  It can be effective in a situation where the neutral has tried many similar cases or otherwise knows the case well.

 

      E. Appraisal

            Appraisal involves the valuation or estimation of the value of property by disinterested persons of suitable qualifications.[11]  It uses expert opinion, rather than explicit market transactions, in order to ascertain the value of an asset or liability.  Appraisals usually relate to leases, real estate, losses and damages under insurance policies or purchase and sale agreements.  Appraisals involve questions of value, price, amounts, damages, and other similar areas of dispute.

            The appraiser is selected or appointed by a competent authority to arrive at a just and true valuation of property.  Appraisers are selected for their special knowledge of the subject matter.  An appraisal may be conducted without formal hearings, and the appraiser is permitted to make his or her own investigation and to establish his or her own procedures.

            The appraiser’s decision need not assume any particular form.  However, an appraisal award may be invalid if it is outside the scope of the issues submitted to the appraiser.  An appraisal made within the scope of the submission is not invalid because the appraiser was mistaken as to law or fact.[12]

            Appraisal differs from arbitration in that an arbitration award is the judgment of a tribunal selected by the parties to determine matters actually in variance between them, whereas an appraisal settles the price or value of property or a claim.[13]  In the appraisal, the appraiser is empowered only to settle the price or value of the property or claim in issue.

            Unless express provision is made for a hearing, the method of determining the facts in an appraisal is left to the appraiser.[14]  The decision may be made without notice to the parties and without a hearing, unless such notice or hearing is required by an express provision in the agreement between the parties.[15]  In addition, the appraisal may be made upon such principles as the appraiser sees fit to adopt, or upon such evidence as the appraiser chooses to receive.  Appraisers are not required to take an oath and are not obliged to provide formal notice or to hear evidence.  They usually proceed by ex parte investigation, so long as the parties are given an opportunity to furnish information and explanation regarding the matters in issue.[16]

            An appraisal resolves only the specific issues of actual value or loss or damages.  All other issues are reserved for determination in a more complete and formal hearing on the merits.[17]  Generally, a dissatisfied party who participates in the selection of an independent appraiser has no greater right to challenge the appraiser’s valuations than that party would have to attack an arbitrator’s award. However, notwithstanding that the award may be fair on its face, a court may consider the method by which the appraiser reached his or her decision.[18]  Where the evidence shows that the appraisal was the result of fraud, corruption, dishonesty or bad faith, a court is justified in overturning the appraiser’s determination, even though the appraiser was selected by agreement between the parties.[19] 

            It should also be noted that a court is without power to enter a judgment upon an appraisal report as if it were an arbitration award. The proper remedy is to commence an action involving a complete and formal trial on the merits.[20]

 

            F. Arbitration

            Arbitration is a method for dispute resolution in which the parties submit their dispute to an impartial person selected by the parties.[21]  The parties may use a single arbitrator to hear a dispute or they may use an arbitration board or panel.  The arbitrator makes a decision following a hearing.  In binding arbitration (usually referred to simply as “arbitration”), the arbitrator’s decision is final and binding on the parties.

            The arbitrator hears evidence from each side and renders a decision that is normally binding on the parties, as noted above.  The procedure is less formal than a judicial trial.  Unless the parties agree to the contrary, the arbitrator is not bound to follow the law.  Instead, the arbitrator may base the decision on business custom and practice, technical insight, or broad principles of equity and justice.  Once confirmed, an arbitrator’s award is enforceable in the same manner as a court judgment.[22]

            The process in non-binding arbitration is the same as binding arbitration, except that the arbitrator’s decision is advisory only.  If the parties do not accept the decision, the advisory decision may be used as an aid to resolve the dispute through negotiation or other means.[23]  Incentive arbitration is a form of non-binding arbitration in which the parties agree to the imposition of a penalty on the party who rejects the arbitrator’s advisory decision and pursues its claim in court, if that party does not improve its position by some percentage or formula.  The penalties may include payment of attorney fees in the litigation or payment of the full cost of arbitration.

            Compulsory arbitration results when a statute or administrative rule or regulation requires certain types of disputes to be submitted to arbitration.  In voluntary or contractual arbitration, the parties mutually agree that an issue may be submitted to arbitration.  The parties either contractually agree to submit future disputes to arbitration or they agree to submit an existing dispute to arbitration.

 

            G. Mediation-Arbitration

            Mediation-arbitration, sometimes referred to as “med-arb,” is a mixed process that begins as mediation and ends with arbitration if the mediation is unsuccessful.[24]  Mediation-arbitration is used most commonly in labor-management disputes.  It is supported by the theory that, under the threat of arbitration, the participants will try harder to achieve voluntary settlement of the dispute. 

            Mediation-arbitration involves a two-step process.  First, a neutral third party mediates the dispute with the parties in an attempt to reach a voluntary settlement. Subsequently, if the participants remain at impasse, the neutral renders a binding decision on the unresolved issues following an arbitration hearing.  Mediation-arbitration is particularly effective when the participants are of relatively equal bargaining experience; the efficiency of a combined procedure outweighs the inhibiting effect of the mediator’s anticipated role change.[25]

            The arbitrator may be the person who conducts the mediation or the parties may select one person to mediate and another person to arbitrate.  A person who acts as mediator and then as arbitrator is known as the mediator-arbitrator.  Some contend that using the same person to mediate and to arbitrate is advantageous because the neutral has more leverage in the mediation process -- the parties know a solution will be imposed upon them if they do not arrive at one of their own.  Others assert that mediation-arbitration compromises the integrity of the mediation process and the arbitrator’s neutrality.  The neutral may have received confidential information relevant to the merits of the dispute in the course of mediation before deciding the arbitration.

            Because of this concern about the integrity of the process, some agreements provide for one person to mediate and a different person to arbitrate. However, this remedy is more costly and time consuming than using the same person as both mediator and arbitrator.  In addition, it does not allow for further attempts to mediate once the process reaches arbitration.[26]  However, the use of different persons as the mediator and the arbitrator is appropriate if the parties are concerned about the perceived bias of the mediator-arbitrator.[27]

 

            H. Minitrials

            The minitrial is not a trial, per se.  It is a structured dispute-resolution method in which senior executives of the parties involved in a legal dispute meet in the presence of a neutral advisor. After hearing presentations on the merits of each side, these representatives attempt to formulate a voluntary settlement.[28]  The minitrial is a form of facilitated negotiation and includes elements of negotiation and adversarial case presentation.

            The minitrial was developed in the corporate setting.  Minitrials are usually employed to resolve disputes that would otherwise involve lengthy litigation.  The senior executives selected to participate by the parties should hold no direct involvement in the dispute, lest they feel a need to defend past actions.  The more senior the management representatives, the greater the range of options available for a constructive solution.

            The parties should agree in writing that the minitrial proceedings are confidential and that no written or oral statement made by any participant can be used as evidence or an admission in other proceedings.  The fees and expenses of the neutral advisor are borne equally by the parties.  Each party normally is responsible for its own costs, including legal fees, incurred by participation in the minitrial.  In their written agreement, the parties may alter the allocation of fees and expenses.

 

            I. Early Neutral Evaluation

            Early neutral evaluation is a court-annexed settlement program used to assist the parties in developing an approach to the litigation that focuses on key issues and necessary discovery.[29]  The parties may hire, or the court may appoint, a neutral evaluator (such as an attorney), who is highly experienced with the subject to conduct a review of the matter in dispute. 

            The evaluator appraises the merits of the dispute and makes suggestions for conducting discovery and obtaining legal rulings to resolve the case efficiently.  The evaluator helps the parties identify areas of agreement, assess the strengths and weaknesses of their arguments and their evidence, and devise a plan for sharing important information and conducting key discovery.  The neutral evaluator’s report may also aid the parties in reaching a settlement.  If the case does not settle, the report remains confidential.  The evaluator then helps the parties to simplify and adapt the case for more expeditious handling in trial.

 

III.

Federal Law

Traditionally, courts refused to enforce agreements to arbitrate.[30]  The Federal Arbitration Act of 1925[31] (also referred to as the United States Arbitration Act)[32] changed the common law rule.  It made a written agreement to arbitrate specifically enforceable in the federal courts, so long as the agreement is connected with a maritime transaction or evidences a transaction involving foreign or interstate commerce.[33]  By adopting the Act, Congress intended to create a new body of federal substantive law affecting the validity and interpretation of arbitration agreements.  It also sought to exercise its full range of constitutional power under the commerce clause in order to make the Act as widely effective as possible.[34]  The Act applies in state courts as well as in federal courts.[35]

            The purpose of the Act is to relieve congestion in the courts and to provide parties with an alternative method for dispute resolution that would be more efficient and less costly than litigation.[36]  It recognizes a strong public policy favoring arbitration of maritime and commercial disputes.[37]  The Act intends for the courts to enforce arbitration agreements into which parties have entered[38] and to place such agreements upon the same footing as other contracts.[39]  All doubts as to arbitrability under the Act are construed in favor of the liberal policy of promoting arbitration.[40]

            Section 4 of the Act, allowing a party to petition the district court for an order compelling arbitration, does not create independent federal jurisdiction.[41]  In order to establish federal jurisdiction, the party seeking to compel arbitration must demonstrate that, if there were no agreement to arbitrate, a federal court would have jurisdiction “of the subject matter of a suit arising out of the controversy between the parties.”[42] 

However, Section 4 has been interpreted to mean that a federal court has subject matter jurisdiction over an action to compel or stay arbitration merely because the underlying claim raises a federal question.  A petition under Section 4 must be brought in state court unless some other basis of federal jurisdiction exists, such as diversity of citizenship or assertion of an admiralty claim.[43]

            The Act applies to contracts “evidencing a transaction involving [interstate] commerce.”[44]  The Federal Arbitration Act is the only federal statute using the phrase “involving” to represent an interstate commerce relationship.[45]  Since the enactment of the Act, federal and state courts have differed as to when a transaction “involves” interstate commerce to such an extent that the Act applies.[46]

            In Allied-Bruce Terminix Companies, Inc. v. Dobson,[47] the United States Supreme Court held that the words, “involving commerce,” as used in the Act, are the functional equivalent of “affecting commerce,” signaling Congress’ intent to exercise its commerce power to the full.  The Court rejected the “contemplation of the parties” standard, which provides that the Act applies only if the parties contemplated substantial interstate activity.  The Supreme Court applied a “commerce in fact” standard, noting that the transaction must have involved interstate commerce, even if the parties did not con­tem­plate an interstate commerce connection.[48]

            The United States Supreme Court added further clarification in Prima Paint Corp. v. Flood & Conklin Manufacturing Co.,[49] declaring that the Federal Arbitration Act “is based upon and confined to the incontestable federal foundations of ‘control over interstate commerce and over admiralty.’”[50]  The Court rejected the argument that the transactions involving commerce covered by the Act are limited to contracts between merchants for the interstate shipment of goods.  Acknowledging that the Act articulates substantive law, the Court determined that the Act applied in diversity cases because Congress had intended that result.  The Court explained, “Congress may prescribe how federal courts are to conduct themselves with respect to subject matter of which Congress plainly has power to legislate.”[51]

            In Southland Corp. v. Keating,[52] the United States Supreme Court addressed an additional question about whether the Act preempts conflicting state anti-arbitration law, or whether state courts could apply their own anti-arbitration statutes in pending cases, thereby reaching results different from those reached in similar federal diversity cases.  Declaring that Congress would not have wanted state and federal courts to reach different outcomes about the validity of arbitration in similar cases, the Court concluded that the Federal Arbitration Act preempts state law and is applicable in both state and federal courts.[53]

            Furthermore, although traditional state law contract defenses, such as fraud, duress or unconscionability, may apply to invalidate arbitration agreements without contravening the Act, a court may not invalidate arbitration agreements under state laws applicable only to arbitration provisions.[54]  In Doctor’s Associates, Inc., v. Casarotto, franchisees brought an action in state court against a franchisor and its agent involving a dispute under a standard form franchise agreement.  The state trial court stayed the action pending arbitration, and the franchisees appealed.  The Montana Supreme Court reversed, finding that the arbitration clause was unenforceable under a state statute that conditioned enforceability of arbitration agreements on compliance with a special notice requirement not otherwise applicable to contracts generally.[55]

            The United States Supreme Court held that Montana’s special notice requirement was preempted by the Federal Arbitration Act.[56]  The Court explained that, by enacting Section 2 of the Federal Arbitration Act, Congress precluded states from singling out arbitration provisions for suspect status, requiring instead that such provisions maintain the same status as other contracts.[57] The Court affirmed that the Montana provision directly conflicted with Section 2 of the Act because the Montana law conditioned the enforceability of arbitration agreements on compliance with a special notice requirement not applicable to contracts generally.[58]

            The Federal Arbitration Act does not mandate arbitration of all claims.  Without an agreement to arbitrate, the Act does not apply, and the parties are then entitled to a judicial remedy.[59]  Since arbitration arises through contract, parties are essentially free to define for themselves what questions may be arbitrated, the remedies an arbitrator may afford, and the extent to which the decision must conform to general principles of law.[60]  However, it has been held that arbitrators are without authority to decide constitutional issues irrespective of the contractual language.[61]

            The McCarran-Ferguson Act[62] exempts certain insurance practices from federal law (including the Federal Arbitration Act),[63] and makes state law supreme.[64]  An agreement between an insurer and an insured to arbitrate claims arising out of insurance coverage should be considered as involving the “business of insurance,” as that term is used in the Act.[65]  However, there are few cases holding that the arbitration of claims is or is not the business of insurance.[66]

            There is little case law on the applicability of the Federal Arbitration Act to individual insurance contracts.[67]  In addition, much of the insurance business is exempt from otherwise applicable federal law under the McCarran-Ferguson Act.[68]  In United States v. South-Eastern Underwriters Association,[69] the United States Supreme Court determined that, even if an individual insurance contract could be seen as “local” rather than “interstate” commerce, the broader business of insurance nonetheless was interstate commerce.[70] 

            Some courts have upheld the application of the Federal Arbitration Act to reinsurance agreements.[71]  Only a few cases involving individual insurance policies have arisen under the Federal Arbitration Act.  Hart v. Orion Insurance Co.[72] involved a disability insurance policy.  The insurance company had sought and obtained a court order compelling arbitration.  The insured appealed, asserting that the arbitration agreement was unenforceable.  On appeal to the Tenth Circuit, the court held that the Federal Arbitration Act applies whenever interstate commerce is involved. Such involvement existed in this case by virtue of an interstate delivery of the insurance policy.[73]

            Congress passed the McCarran-Ferguson Act[74] in response to South-Eastern Underwriters.[75]  The Act is intended to exempt the insurance industry from most federal antitrust laws and to return to the states some of their regulatory authority prior to South-Eastern Underwriters.  How much authority Congress intended to return to the states is still unclear.[76]

            In the McCarran-Ferguson Act, Congress ceded to the states the primary responsibility for regulating the insurance business and it provided an exemption, under certain circumstances, from application of federal law.[77]  In order to establish that an activity is exempt from a particular federal law, three conditions must be met:  (1) the federal law in question does not specifically relate to the business of insurance; (2) the activity in question is the “business of insurance;”[78] and (3) the application of federal law would invalidate, impair or supersede state regulation of the activity.[79]

            Since the Federal Arbitration Act does not specifically relate to the business of insurance,[80] the first criterion is readily satisfied in cases involving the Federal Arbitration Act and insurance disputes.  Most controversies regarding application of the McCarran-Ferguson Act involve the second and third criteria.[81]

            In determining whether a particular practice is part of the “business of insurance,” one court has suggested that the following three factors should be considered:

 

  1. Whether the practice has the effect of transferring or spreading a policyholder’s risk;
  2. Whether the practice is an integral part of the policy relationship between the insurer and the insured; and
  3. Whether the practice is limited to entities within the insurance industry.[82]

IV.

Application of Alternative Dispute

Resolution to Insurance Claims

A. Personal Injury Claims

            Many personal injury claims are suitable for alternative dispute resolution.[83]  If utilized properly and with the right type of claim, alternative dispute resolution can be important in securing the just, speedy, and inexpensive determination of a claim.  Mediation can be used to resolve personal injury claims.[84]  Mediated personal injury claims generally have three characteristics:[85]

 

  1. the claimant typically is inexperienced in resolving personal injury disputes;[86]
  2. the negotiations usually only involve the distribution of funds from one party to the other, and
  3. the issue being mediated is largely subjective.

 

            Liability is typically stipulated by the parties before entering an agreement to mediate a personal injury claim.[87]  In addition, the issue of who pays for any alleged damages is usually established before mediation. Thus, the defendant frequently is not present at the mediation session.  The plaintiff, the plaintiff’s attorney, the defendant’s attorney and an adjuster from the defendant’s insurer will focus on the issue of damages.

            Because the mediation involves a claimant who is probably involved in a single lawsuit necessitating evaluation, while the insurance representative may have handled hundreds of similar cases, the mediator is challenged to bring some balance to the playing field.  For this reason, it may benefit the plaintiff to be represented by a lawyer.

            The distributive nature of personal injury disputes requires the mediator to determine how to facilitate give-and-take when the claim involves only how much the defendant will pay and how much the claimant will accept.  The subjective nature of the personal injury dispute involves the claimant’s pain and suffering.  The mediator is challenged to find suitable criteria that will help the parties place an acceptable value on pain and suffering.

            The mediation session usually begins with a joint session at which both parties provide a brief overview of their issues and arguments.[88]  The mediator may then caucus separately with each party to discuss each side’s concerns.  At the mediation session, the plaintiff may present a settlement package, including all medical records and billings as well as other records of special damages to provide the mediator with access to the records as the case is being discussed.  It is important for the mediator to establish communication and rapport as soon as possible.[89]  Although distributive interests constitute a large segment of personal injury mediation, the mediator should help the parties identify the other interests involved.[90]  These interests may include the desire for an admission of fault or an apology.

            An unresolved issue of liability often precludes the use of mediation and requires the use of binding arbitration.[91]  Cases involving substantial medical expenses with no objective findings of injury, and cases involving minor impacts, are often more suitable to arbitration because the defendant is sometimes reluctant to accept the claim or the extent of the claim.[92]

            Initially, the parties enter into a written arbitration agreement, establishing the procedural rules, rules for conduct of the hearing, powers of the arbitrator, enforceability of the award, method of selecting the arbitrator, and any other terms and conditions to arbitration.[93]  At the arbitration hearing, the parties present material evidence and cross-examine opposing witnesses.[94]

            Under the rules of the American Arbitration Association, insurers or claimants start the process by sending the following information to the nearest AAA office: