Mark Gray v. Tyson Foods, Inc.

This case addresses whether the Uniform Arbitration Act confers subject matter jurisdiction on Tennessee courts to confirm an arbitration award when the parties' arbitration agreement specified that arbitration would occur in another state. Berkeley Research Group, LLC and Southern Advanced Materials, LLC entered into a contract which provided that any dispute would be resolved by arbitration in Pennsylvania, not Tennessee. A dispute arose and the parties entered arbitration, which resulted in an award to Berkeley. Berkeley sought to confirm the arbitration award in Shelby County Chancery Court. The trial court confirmed Berkeley's arbitration award and entered judgment. The Court of Appeals reversed, finding that while the trial court had subject matter jurisdiction, it lacked personal jurisdiction over Southern. We find that Tennessee courts lack subject matter jurisdiction to confirm an arbitration reward when the parties agreed arbitration would occur in another state. As a result, the trial court lacked jurisdiction to confirm an award resulting from an arbitration the parties agreed would occur in Pennsylvania. We vacate the judgments of the lower courts and dismiss the petition to confirm the award.

Belinda LeMaire ("Employee") sustained an injury to her right foot while working forLowe's Home Centers, LLC ("Employer"). The claim was accepted as compensable, andthe Court of Workers' Compensation Claims ("trial court") entered a compensation orderawarding permanent-partial disability benefits along with future reasonable and necessaryrnedical benefits. Employee subsequently filed a petition for benefit determination statingthat she had been discharged by her treating physician, and Employer was refusing toprovide additional medical treatment. Following a hearing, the trial court ordered Employerto provide Employee with a new panel of physicians qualified and willing to treat her workrelatedinjury. The Workers' Compensation Appeals Board ("Appeals l3oard") affirmed.Employer has appealed and the appeal has been referred to the Special Workers'Compensation Appeals Panel pursuant to Tennessee Supreme Court Rule 51. We affirmthe judgment of the Appeals Board and adopt its opinion as set forth in the attachedAppendix.