Claimant, John T. Hays, M.D. (“Hays”), is a cardiologist in Texas with over thirty years in medical practice. He began suffering from epilepsy and taking medication in 1998. Dr. Hays’s seizures were well-controlled but “exacerbated by stress.” In 2006, Hays’s practice was purchased by Austin Heart, P.L.L.C. (“Austin Heart”), and Hays informed Austin Heart’s managing director of his condition and requested a less demanding schedule. In 2009, Austin Heart and Capital Area Cardiology (“CAC”) entered into a Physician Employment Agreement (“Agreement”) with Dr. Hays containing an arbitration clause. In December 2013, Hays experienced seizures for two days. He was then put on administrative leave by Defendants HCA Holdings, Inc. and HCA Physician Services, Inc., and his employment was terminated in January 2014.

Dr. Hays alleged wrongful termination against his former employer based on his stress-related seizures. Hays’s employment agreement, to which Hays, Austin Heart, and CAC were signatories, contained an arbitration clause “providing that any ‘controversy or claim arising out of or related to’ the Agreement will be submitted to mandatory, binding arbitration before the American Health Lawyers Association (AHLA).”Hays initially brought claims against CAC, Austin Heart, and HCA Holdings. As signatories to the Agreement with Hays, the state court granted CAC and Austin Heart’s motion to dismiss and compel arbitration. Hays then amended his state court complaint against HCA Holdings, Inc. and added HCA Physician Services, Inc. (collectively “HCA”) as a defendant. HCA removed the case to federal court. Among Hays’s added claims against HCA was tortious interference with at-will employment.4The Western District of Texas applied direct benefits estoppel and required the parties to arbitrate “[b]ecause HCA’s liability under the tortious interference claim could not ‘be determined without reference to the Physician Employment Agreement.'” Hays appealed to the Fifth Circuit Court of Appeals (“Fifth Circuit”), which reviews “an order compelling arbitration de novo,” and claimed that the district court abused its discretion when it compelled arbitration under equitable estoppel. The Fifth Circuit found that “HCA’s liability depends on the Agreement” and that “the district court did not abuse its discretion in applying direct benefits estoppel to Hays’s tortious interference claim.”

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