Fields v. Herrnstein Chrysler, Inc.
2013 Ohio 693
Ohio Ct. App.2013Background
- Fields bought a 2010 Jeep Grand Cherokee from Herrnstein Chrysler, financed by Capital One Auto Finance, with an arbitration clause in the financing contract.
- A separate “Agreement to Arbitrate” was signed the same day by Fields and Herrnstein.
- After paint defects, Fields sued multiple defendants including signatories and non-signatories to arbitration.
- Defendants moved to stay and compel arbitration under the arbitration agreements.
- The trial court held the Agreement to Arbitrate valid and ordered arbitration for certain nonsignatories via estoppel, with some claims stayed.
- Fields appeals, arguing the court rewrote the arbitration agreement and improperly compelled non-signatories.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the trial court rewrite the arbitration agreement by including nonsignatories? | Fields argues nonsignatories were not signatories. | Appellees say estoppel allows enforcing against nonsignatories. | No reversible error; affirmed order under estoppel. |
| Was Chrysler Group, LLC properly compelled despite not being a signatory? | Chrysler Group, LLC is not bound by the contract. | Close relationship and intertwined claims justify estoppel. | No reversible error; arbitration proper under estoppel. |
| Standard of review for order to compel arbitration | Abuse-of-discretion review; deferential but principled. |
Key Cases Cited
- Grigson v. Creative Artists Agency, L.L.C., 210 F.3d 524 (C.A.5, 2000) (substantially interdependent misconduct; intertwined claims)
- Thomson-CSF, S.A. v. Am. Arbitration Assn., 64 F.3d 773 (C.A.2, 1995) (alternate estoppel theory for nonsignatories)
- Sunkist Growers, Inc. v. Sunkist Soft Drinks, Inc., 10 F.3d 753 (C.A.11, 1993) (intertwined contract obligations and arbitration)
- MS Dealer Serv. Corp. v. Franklin, 177 F.3d 942 (C.A.11, 1999) (intertwined and concerted misconduct possible under estoppel)
- Hill v. G.E. Power Sys., Inc., 282 F.3d 343 (C.A.5, 2002) (twined claims; signatory relies on agreement terms)
- Tomovich v. USA Waterproofing & Foundation Services, Inc., 2007-Ohio-6214 (9th Dist.) (arbitration stay when issue referable to arbitration)