42 F.4th 868
8th Cir.2022Background:
- Maggie Triplet, a person with severe autism, was under a South Dakota guardianship and conservatorship (mother Mary appointed) but the guardianship did not expressly strip her of contractual capacity.
- A state-sponsored job coach accompanied Maggie to a Menards job fair and orientation; Menards refused the coach's assistance and Maggie signed an employment agreement (including an arbitration clause) without review.
- While employed, Maggie was involved in an incident where manager Barb Myers restrained her and she was presented with resignation papers, which she signed without consulting her guardian or coach.
- Maggie and Mary sued Menard and Myers under the ADA and for state torts (assault, battery, intentional infliction of emotional distress); Menard/Meyers moved to compel arbitration based on the employment agreement.
- The district court denied the motion to compel arbitration, reasoning the clause was unenforceable in equity, Myers could not enforce as a non‑signatory, and tort claims were outside arbitration; Menard appealed.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Enforceability of arbitration agreement under state law (capacity/void contract) | Triplet lacked capacity / was effectively incapable to contract due to guardianship and disability; agreement unenforceable | Agreement valid on its face; guardianship did not remove contractual capacity; FAA requires enforcement absent a state‑law defense | Court: District court failed to apply South Dakota contract law; remanded for a bench (summary) trial to determine if Triplet was "entirely without understanding" when she signed (void contract inquiry) |
| Applicability of the FAA (federal policy favoring arbitration) | N/A (argues arbitration unenforceable) | FAA requires courts to compel arbitration where a valid agreement exists and covers the dispute | Court: Reinforced FAA principles but concluded factual findings under state law are necessary before compelling arbitration |
| Non‑signatory enforcement by Myers | N/A (plaintiff opposes enforcement) | Myers argued she could enforce the clause despite not signing | Court: Declined to decide on appeal because enforceability of the agreement itself must be resolved first; left for district court if necessary |
| Scope of arbitration (whether state tort claims are arbitrable) | Tort claims should be litigated, not arbitrated | Employment agreement covers disputes; arbitration should encompass these claims | Court: Did not resolve; remanded for deciding enforceability first and then scope under FAA and state law |
Key Cases Cited
- 3M Co. v. Amtex Sec., Inc., 542 F.3d 1193 (8th Cir.) (motion to compel arbitration standard)
- Moses H. Cone Mem’l Hosp. v. Mercury Constr. Corp., 460 U.S. 1 (U.S.) (federal policy favoring arbitration; doubts resolved for arbitration)
- Pro Tech Indus., Inc. v. URS Corp., 377 F.3d 868 (8th Cir.) (court must compel arbitration where valid clause exists)
- AT&T Mobility LLC v. Concepcion, 563 U.S. 333 (U.S.) (FAA savings clause allows generally applicable contract defenses)
- First State Bank of Sinai v. Hyland, 399 N.W.2d 894 (S.D.) (void contract doctrine for mentally incompetent contracting)
- Neb. Mach. Co. v. Cargotec Sols., LLC, 762 F.3d 737 (8th Cir.) (remand for district court to hold bench trial and make findings on arbitration issues)