HEB Grocery Company L.P. v. Maria Del Rosario Del Cid
Juan Del Cid Castillo sued HEB Grocery Company, L.P. for negligence after sustaining workplace injuries. His wife, Maria Del Rosario Del Cid, filed a derivative loss of consortium claim within the same lawsuit. HEB moved to compel arbitration for Juan's claim and to stay Maria's claim, citing an arbitration agreement signed by Juan. The trial court granted arbitration for Juan but denied HEB's motion to stay Maria's claim. HEB appealed this denial. The Fourth Court of Appeals in San Antonio determined that Maria's loss of consortium claim is derivative, shares operative facts, and is inherently inseparable from Juan's arbitration claim, thus falling under the mandatory stay provisions of the Federal Arbitration Act. Consequently, the appellate court reversed the trial court's order and remanded the case, directing the trial court to stay all proceedings related to Maria's claim pending the outcome of Juan's arbitration.