Matter of Monarch Consulting, Inc. v. National Union Fire Ins. Co. of Pittsburgh, PA.
Justice Gische dissents from the majority's decision, arguing that arbitrators, not the court, should determine the enforceability of payment agreements containing arbitration clauses in workers' compensation cases. The dissent highlights that the payment agreements were not filed with the Workers’ Compensation Insurance Rating Bureau (WCIRB), an issue the insureds use to invalidate the arbitration provisions. Citing the Federal Arbitration Act (FAA) and Supreme Court precedent, Gische, J. contends that challenges to the contract as a whole should be decided by arbitrators. Furthermore, the dissent disagrees with the majority's application of the McCarran-Ferguson Act, asserting that California law does not prohibit arbitration in insurance disputes and that arbitration does not undermine filing requirements. The dissent critiques the Ceradyne decision as inconsistent with Supreme Court rulings on severability and arbitrability.