Buckhorn v. St Jude Heritage Medical Group

In Buckhorn v. St. Jude Heritage Medical Group (2004) 121 Cal.App.4th 1401, a doctor entered into an employment contract with a medical group. The contract provided, "In the event that a dispute arises between the parties concerning the enforcement or the interpretation of any provisions of this Agreement, such dispute shall be submitted to arbitration for resolution." (Id. at p. 1404, fn. 1.) After the medical group terminated his employment, the doctor filed an action against the group in which he alleged claims including fraud in the inducement, wrongful termination, defamation, and intentional and negligent interference with prospective business advantage. (Id. at p. 1405.) In his complaint, the doctor alleged that the group had published a letter to his patients explaining that he had the left the group because of "marital problems, mental problems, loss of his insurance coverage, and that he was no longer practicing medicine. . . ." (Ibid.) The Buckhorn court rejected the doctor's contention that the arbitration clause was too narrow to encompass tort claims premised on acts that occurred after his termination, reasoning: "The issue turns on whether the tort claims are 'rooted' in the contractual relationship between the parties, not when they occurred. For example, Buckhorn's claims for intentional and negligent interference with prospective economic advantage were based on an expectation of future income from his patients. But Buckhorn's patients consulted him in his capacity as an employee of the Medical Group and therefore the employment agreement would inform the extent of any economic interest. Because Buckhorn failed to demonstrate his tort claims were 'wholly independent' of the employment agreement, and any doubts must be resolved in favor of arbitration (Vianna, supra, 27 Cal.App.4th at p. 1189), we conclude all of Buckhorn's claims must be submitted to arbitration." (Buckhorn, supra, 121 Cal.App.4th at pp. 1407-1408.) The Court rejected a plaintiff's attempt to impose a temporal standard between events occurring while an arbitration clause was in effect and events occurring at a later date. In Buckhorn, the plaintiff, a doctor, signed an employment contract with a medical group providing for arbitration "'in the event that a dispute arises between the parties concerning the enforcement or the interpretation of any provisions of this Agreement. . . .'" (Id. at p. 1407.) The plaintiff argued the arbitration clause did not apply to his additional disputes against the medical group for defamation based on events occurring after his termination. We disagreed, holding that the plaintiff's temporal test "misconstrues the applicable standard. The issue turns on whether the tort claims are 'rooted' in the contractual relationship between the parties, not when they occurred. For example, the plaintiff's claims for intentional and negligent interference with prospective economic advantage were based on an expectation of future income from his patients. But the plaintiff's patients consulted him in his capacity as an employee of the Medical Group and therefore the employment agreement would inform the extent of any economic interest. Because the plaintiff failed to demonstrate his tort claims were 'wholly independent' of the employment agreement, and any doubts must be resolved in favor of arbitration, we conclude all of plaintiff's claims must be submitted to arbitration." (Id. at pp. 1407-1408.)