The award limits an arbitrator could grant ended up deciding the venue
A Connecticut appellate court ruled on August 11, 2026 that a radiologist's noncompete dispute belonged in court, not before an arbitrator.
The physician became part of RAH Equity Holdings in March 2022 through a purchase-and-sale deal, selling his stake in certain nonclinical assets to Premier Imaging Holdings. The agreement he signed carried two clauses that would matter later: a noncompete barring him from competing for two years within a set territory if he left, and an arbitration clause that incorporated the American Arbitration Association's (AAA) commercial rules.
He gave notice in 2023 and resigned in April 2024, joining another medical practice soon after. RAH Equity and Premier, both Delaware companies, answered by starting an AAA arbitration. They wanted a declaration that the noncompete was enforceable and that his new job breached it.
The radiologist refused to arbitrate. He filed in Superior Court, arguing the arbitrators had no authority to issue that kind of ruling. The trial court sided with him, and the Appellate Court affirmed.
The decision turned on two wording questions. The first was who gets to decide whether a dispute is even arbitrable - a court or an arbitrator. Because the agreement selected Delaware law, the court followed Delaware's rule. Pointing to the AAA rules, on its own, did not hand that question to an arbitrator. The clause did not sweep in every dispute; it let parties go to court for injunctive relief and limited an arbitrator's awards to money damages, fees, and sanctions. That left the court to decide arbitrability.
The second question was whether the noncompete claim belonged in arbitration at all. The companies had sought only a declaratory ruling, nothing else. The clause gave an arbitrator no power to grant that relief, so the court found the claim was not arbitrable. The AAA then dismissed the arbitration.
The court did not rule on the noncompete itself - whether it was valid, or whether it had been broken. A footnote pointed to Connecticut's statute capping physician noncompetes at one year or a fifteen-mile radius, and to the Federal Trade Commission's nationwide noncompete ban, which never took effect after a court set it aside and was rescinded by the agency in February 2026. The agreement still allowed either side to bring an injunctive-relief dispute to court.
