In Government Employees Insurance Company v. Mount Prospect Chiropractic Center, No. 23-1378 (3d Cir. Apr. 26, 2024), a decision resolving appeals in multiple cases, the Third Circuit reversed the district courts’ decisions that GEICO’s claims under the New Jersey Insurance Fraud Prevention Act (IFPA) were not subject to arbitration. The defendant health care providers moved to compel arbitration on the ground that their contracts with GEICO required arbitration of any disputes arising under the agreements or relating to claims for insurance benefits. The defendants also argued that a New Jersey statute relating to no-fault automobile insurance required arbitration of the claims.

The Third Circuit held that both the contracts and the statute independently required arbitration. As explained in this article, however, the Third Circuit had appellate jurisdiction under the Federal Arbitration Act (the FAA) to decide only whether the claims were arbitrable under a written arbitration agreement. Whether the New Jersey no-fault statute mandates arbitration of IFPA claims—a hotly debated issue of New Jersey state law—was outside the scope of that jurisdiction. This jurisdictional issue was not discussed in the opinion or the parties’ briefs.

Background to ’GEICO’ Decision