Community Bank of Mississippi v. Stuckey, 52 So. 3d 1179

Donna and Mike Stuckey operated Stuckey Farms; Raymond McAlpin partnered with them through Community Bank loans.
Four loans are at issue: three cattle-business loans and one eleven-acre deed of trust on Appleridge Estates, LLC property; all four contain arbitration agreements.
Donna alleges forged signatures on the arbitration agreements and that McAlpin misrepresented the eleven-acre property to induce execution of the deed of trust.
Bank sought to compel arbitration; trial court found no convincing evidence that Donna signed the arbitration agreements and denied arbitration as to Donna.
Court of Appeals reversed, holding Donna bound to arbitration as a third-party beneficiary and equitably estopped from challenging arbitration.
Mississippi Supreme Court granted certiorari and held that the trial court’s findings were not clearly erroneous and Bank lacked clean hands to compel arbitration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Donna sign the Appleridge Estates arbitration agreement?	Stuckey asserts Donna signed the Appleridge arbitration agreement.	Stuckey argues the May 12, 2003 documents include Donna’s signature as a Participant.	No clear error; Donna did not convincingly sign the Appleridge agreement.
Did Donna sign the June 2003 cattle-loan arbitration agreement?	Arbitration agreement existed and Donna signed it relating to loan 6803148.	Donna did not sign the specific June 2003 loan arbitration; experts reviewed different documents.	The trial court did not clearly err; Donna did not sign the June 2003 arbitration agreement.
Should Donna be bound to arbitrate as a third-party beneficiary?	Donna could enforce arbitration as a third-party beneficiary of the loan documents.	Donna cannot be bound due to forged signatures and lack of clean hands by Bank.	Bank’s unclean hands prevent enforcing arbitration as a third-party beneficiary.
Should Donna be bound to arbitrate under equitable estoppel?	Equitable estoppel could require Donna to arbitrate despite lack of signed agreements.	Equitable estoppel not appropriate given forgeries and improper conduct by Bank.	Equitable estoppel not applicable due to Bank’s forged signatures and lack of clean hands.

UHS-Qualicare, Inc. v. Gulf Coast Cmty. Hosp., Inc., 525 So.2d 746 (Miss. 1987) (clearly erroneous standard for trial court findings)
Qualcomm v. American Wireless Group, 980 So.2d 261 (Miss. 2007) (third-party-beneficiary arbitration enforcement)
Adams v. Greenpoint Credit, LLC, 943 So.2d 703 (Miss. 2006) (third-party beneficiary theory)
Terminix Int'l, Inc. v. Rice, 904 So.2d 1051 (Miss. 2004) (equitable estoppel principle in contract context)
Pickett v. Boutwell, 125 So.2d 822 (Miss. 1961) (clean hands/relief principle)
Cost Bros., Inc. v. Travelers Indem. Co., 760 F.2d 58 (3d Cir. 1985) (specific performance and clean-hands doctrine)
Washington Mut. Fin. Group, LLC v. Bailey, 364 F.3d 260 (5th Cir. 2004) (equitable estoppel and contract principles)