Justia Missouri Supreme Court Opinion Summaries

Articles Posted in Arbitration & Mediation
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The Supreme Court reversed the rulings of the circuit court denying Bridgecrest Acceptance Corporation's motions to dismiss or stay the counterclaims against it and to compel the matters to arbitration pursuant to an arbitration agreement, holding that the arbitration agreement was legally valid, conscionable, and not precluded by collateral estoppel.In two separate cases, Bridgecrest sought a deficiency judgment against consumers who had defaulted on car payments. The consumers brought counterclaims, raising putative class claims for unlawful and deceptive business practices. Bridgecrest moved to stay or dismiss the consumers' counterclaims and compel arbitration pursuant to the arbitration agreements signed by the consumers when buying their vehicles. The circuit court overruled the motions in both cases. The Supreme Court reversed, holding that the circuit court erred in refusing to compel arbitration. View "Bridgecrest Acceptance Corp. v. Donaldson" on Justia Law

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The Supreme Court affirmed the order of the circuit court confirming an arbitration award in favor of Car Credit, Inc., holding that the arbitration agreement was valid and that the circuit court did not err.Cathy Pitts entered into a retail installment contract and security agreement with Car Credit to purchase and finance a vehicle. The parties also entered into a written arbitration agreement. After Car Credit repossessed the vehicle and sued Pitts for the remaining deficiency balance Pitts filed a counterclaim alleging an unlawful and deceptive pattern of wrongdoing followed by Car Credit. The circuit court sustained Car Credit's motion to compel arbitration. The arbitrator entered an award on the merits' of Pitts' claim in favor of Car Credit. The circuit court entered judgment for Car Credit on all causes of action in accordance with the arbitration award. The Supreme Court affirmed, holding that the arbitration agreement was enforceable. View "Car Credit, Inc. v. Pitts" on Justia Law

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The Supreme Court affirmed the order of the circuit court overruling Dollar Tree's motion to compel arbitration and stay proceedings on a former employee's claim of disability discrimination, holding that the order was supported by substantial evidence, was not against the weight of the evidence, and correctly applied the law.After Plaintiff, Dollar Tree's former employee, brought this complaint Dollar Tree filed a motion to compel arbitration and stay proceedings under an arbitration agreement in the employment contract. The parties, however, disputed whether there was assent to the arbitration agreement. The circuit court denied the motion to compel arbitration after hearing testimony but did not make any findings. The Supreme Court affirmed, holding that there was no clear and unmistakable evidence of the existence of assent to a delegation provision, and therefore, the circuit court could not delegate the matter to an arbitrator whose existence depended upon the agreement. View "Theroff v. Dollar Tree Stores, Inc." on Justia Law

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The Supreme Court reversed the order of the circuit court overruling Appellant's motion to dismiss and compel arbitration, holding that Mo. Rev. Stat. 435.355 obligated the circuit court to order the parties to proceed to arbitration under the circumstances of this case.Prior to his discharge from the hospital, Theron Ingram executed a written Durable Power of Attorney naming Andrea Nicole Hall as his attorney in fact. Ingram was subsequently admitted to Brook Chateau, and Hall executed an arbitration agreement with Brook Chateau on Ingram's behalf. Ingram later filed a petition against Brook Chateau alleging negligence and seeking punitive damages. Brook Chateau responded by filing a motion to dismiss and compel arbitration. The circuit court overruled the motion, and the court of appeals affirmed. The Supreme Court reversed, holding that the circuit court was required under section 435.355 to compel arbitration because Brook Chateau attached a valid arbitration agreement alongside its motion to dismiss and compel arbitration. View "Ingram v. Chateau" on Justia Law

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The Supreme Court quashed preliminary writs issued preventing the circuit court from enforcing its orders sustaining motions to compel arbitration and stay proceedings filed by Dollar General, holding that the circuit court properly sustained Dollar General's motions to compel arbitration, stayed the cases, and ordered the parties to arbitrate the question of whether consideration existed.After Jesse Newberry and Becky Lowrance were discharged from Dollar General, they filed charges of discrimination. Dollar General filed motions to compel Newberry and Lowrance to submit their claims to arbitration and stay further proceedings on the grounds that the employees signed agreements to arbitrate. The circuit court sustained Dollar General's motions to compel. Newberry and Lowrance each sought a permanent writ of prohibition preventing the circuit court from enforcing its orders, arguing that Dollar General failed to meet its burden to show consideration supported either the employee arbitration agreements or the provisions delegating threshold issues of arbitrability to the arbitrator. The Supreme Court held that the circuit court properly sustained Dollar General's motions to compel arbitration and stay the cases. View "State ex rel. Newberry v. Honorable Steve Jackson" on Justia Law

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The Supreme Court reversed the order of the circuit court denying Appellants’ motion to compel arbitration pursuant to Mo. Rev. Stat. 435.440.1, holding that the circuit court erred in refusing to compel arbitration on the basis that the arbitration agreement signed by the parties contained a delegation provision mandating that the arbitrator had exclusive authority to decide threshold questions of arbitrability, holding that the delegation provision was valid and enforceable.Appellant asserted in the circuit court that both the delegation provision and the agreement as a whole lacked mutual obligations and that there was no consideration for either the agreement or the delegation provision. The circuit court agreed with Appellants. The Supreme Court did not, holding that the delegation provision was a mutual promise to arbitrate any threshold questions of arbitrability which may arise, and therefore, the delegation clause was bilateral in nature, and consideration was present. View "Soars v. Easter Seals Midwest" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying Lender’s application to compel arbitration and stay proceedings on the claims brought by Borrower, holding that the plain language of the parties’ arbitration agreement showed they agreed to arbitrate before a specified, but unavailable, arbitrator and no other arbitrator.The contracts between the parties contained an arbitration agreement stating that any dispute between the parties shall be resolved by binding arbitration by the National Arbitration Forum (NAF). Thereafter, NAF entered into a consent decree requiring it immediately to stop providing arbitration services for consumer claims nationwide. After Borrower defaulted, Lender filed suit. Borrower counterclaimed. Lender moved to compel arbitration on Borrower’s counterclaim and asked the circuit court to designate a new arbitrator where NAF was unavailable as an arbitrator. The circuit court denied Lender's application. The Supreme Court affirmed, holding that because Lender made the choice to insist upon NAF, and only NAF, as the arbitration forum, Lender could not now expand the arbitration promise it extracted from Borrower in the agreement. View "A-1 Premium Acceptance, Inc. v. Hunter" on Justia Law

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The Supreme Court declined to grant mandamus relief to the Regional Convention and Sports Complex Authority, which sought a writ to compel the circuit court to stay arbitration of the Authority’s claims in its petition for a declaratory judgment and to reinstate the cause on the circuit court’s docket.The Authority, which leased a training facility to the St. Louis Rams, LLC, filed a three-count petition for declaratory judgment against the Rams seeking to void provisions in the lease. The Rams filed a motion to compel arbitration, asserting that the Authority’s claims fell within the scope of the lease’s arbitration provisions. The circuit court sustained the Rams’ motion to compel arbitration. In this original action, the Supreme Court held that the parties’ intent to arbitrate disputes involving the lease was clear and that any doubt as to arbitrability must be resolved in favor of the application of the arbitration clause. View "State ex rel. Regional Convention & Sports Complex Authority v. Honorable Michael D. Burton" on Justia Law

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Steven Pinkerton sought a writ of mandamus or prohibition requiring the circuit court to overrule a motion to compel arbitration filed by the Aviation Institute of Maintenance (the school). After Pinkerton graduated from the school and received his temporary airman certificate from the federal aviation administration and was still unable to find employment in the aviation field, Pinkerton sued the school. The circuit court sustained the school’s motion to compel arbitration. On appeal, Pinkerton argued that the circuit court erred in sustaining the school’s motion to compel arbitration due to issues surrounding the provision that the parties agreed to delegate threshold issues of arbitrability to the arbitrator. The Supreme Court ruled that the circuit court properly sustained the school’s motion to compel arbitration, holding (1) the arbitration agreement clear and unmistakably evidenced the parties’ intent to delegate threshold issues of arbitrability to the arbitrator; and (2) because Pinkerton’s only specific challenge to the delegation provision was without merit, the delegation provision was valid and enforceable. View "State ex rel. Pinkerton v. Honorable Joel P. Fahnestock" on Justia Law

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In 1998, 52 U.S. states and territories entered into the Master Settlement Agreement (MSA) with tobacco manufacturers (PMs), which released the PMs from tobacco-related consumer protection and product liability lawsuits in return for the PMs’ agreement to make annual payments to the states in perpetuity. This dispute concerned the application of the Non-Participating Manufacturer Adjustment (NPM Adjustment), a provision in the MSA that reduces the amount the PMs must pay to states that failed diligently to enforce certain legislation during a relevant year. PMs, Missouri, and other states arbitrated the dispute. More than twenty states and the PMs entered into a partial settlement agreement, but Missouri and other states did not join the settlement. The arbitration panel found that Missouri was not diligent in enforcing its legislative enactment and that the NPM Adjustment applied. Missouri sought relief. The trial court overruled Missouri’s motion to compel the PMS to engage in a single-state arbitration with Missouri over another dispute regarding application of the NPM Adjustment in a subsequent year but modified the award as requested by Missouri. The Supreme Court affirmed, holding (1) the trial court correctly refused to compel single-state arbitration; and (2) the trial court did not err in modifying the panel’s award. View "State ex rel. Greitens v. American Tobacco Co." on Justia Law