Whether the Texas Supreme Court erred in compelling arbitration and staying the bill of review proceeding

QUESTIONS PRESENTED The Texas Structured Settlement Protection Act, TEX. Civ. PRAC. & REM. CODE §§ 141.001 et. seq. (the “Texas SSPA”), specifically Section 141.004, mandates that a transfer of structured settlement payments (a “transfer”) and an agreement to transfer structured settlement payments (a “Transfer Agreement”) is not “effective” unless approved by a Texas court in a final court order (a “Transfer Order”). A transfer and a Transfer Agreement that has not received court approval under the Texas SSPA is ineffective, void, and contrary to Texas public policy. This case arises out of a bill of review proceeding (the “Bill of Review”) filed by Petitioner Rickey Newsome (“Newsome”), who had signed a Transfer Agreement with RSL Funding, LLC (‘RSL’), to set aside and vacate two conflicting Transfer Orders signed by the same court approximately 10 months apart in a Texas SSPA proceeding, one of which was signed after the trial court lost jurisdiction of the case. In response to the filing of the Bill of Review, RSL sought to compel arbitration. 1. Whether the Texas Supreme Court erred in reversing the Dallas County District Court and the Dallas Court of Appeals, by compelling arbitration in, and staying, the Bill of Review in which Newsome seeks to set aside and vacate two conflicting Transfer Orders. 2. Whether the Texas Supreme Court erred in staying the Bill of Review and compelling arbitration in accordance with a general arbitration clause included in the operative Transfer Agreement, where ii said agreement also included a provision in which the parties agreed that the transaction must be approved in a final court order in accordance with the Texas SSPA. 3. Whether the Texas Supreme Court erred in concluding that the issues raised and asserted by Newsome in the Bill of Review related to classic contract defenses, which can be decided by an arbitrator, rather than contract formation questions, which must be decided by a court.