New certified conflicts

I overlooked three new certified conflict cases in last week's case announcements.

Potential conflict in arbitration case

The Ninth District has just released a decision in Kelsey v. Carrington Homes, Inc., in which it held that a trial court must conduct an evidentiary hearing before compelling the parties to arbitrate a dispute.

This holding appears to conflict with that of at least one other appellate district, and may be a candidate for review by the Supreme Court as a certified conflict.