Pittsburgh Logistics v. B. Keppel Trucking, 1943 WDA 2015

Pittsburgh Logistics Systems (Appellant), a freight broker, began working with B. Keppel Trucking (Appellee) in Sept. 2009; parties agreed orally on initial shipment price and Appellee returned a carrier packet including a Motor Carrier Service Contract (MCSC).
Appellee later performed additional shipments in 2012 for a client (Streamlite); after Streamlite’s insolvency Appellant paid Appellee only a portion of amounts owed and offered $9,812.87 on a $50,513.15 claim.
Appellee demanded arbitration (July 2013); arbitration panel awarded Appellee $50,952.09 plus costs; Appellant’s petition to vacate was denied and the trial court confirmed the award (Dec. 1, 2015).
Central factual dispute: whether a valid arbitration agreement existed—Appellant says the MCSC was unsigned by Appellant and therefore nonbinding (or that Carrier Terms of Use governed); Appellee contends the MCSC and parties’ conduct show mutual assent to arbitrate.
Trial court and Superior Court analyzed mutual assent, signature requirements in the MCSC, timing and delivery of the Carrier Terms of Use hyperlink, and business practices between parties.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a valid agreement to arbitrate existed between the parties	Appellant: MCSC was unsigned by Appellant and thus was a draft/no meeting of minds; Carrier Terms of Use (no arbitration clause) controlled	Appellee: Parties manifested assent to MCSC (returning signed carrier packet, business conduct); Terms of Use were sent after delivery and were not agreed to	Court: MCSC was a binding arbitration agreement based on contract language and parties’ conduct; arbitration award enforceable
Whether signature absence invalidates arbitration agreement	Appellant: absence of Appellant signature means no enforceable contract	Appellee: signature not required unless expressly required; parties’ actions show intent to be bound	Court: absence of a signature was not fatal—the MCSC’s language and conduct established mutual assent and consideration

Bair v. Manor Care of Elizabethtown, PA, LLC, 108 A.3d 94 (Pa. Super. 2015) (discusses when unsigned agreements may be unenforceable and focuses on meeting of the minds rather than mere signature presence)
Socko v. Mid-Atlantic Sys. of CPA, Inc., 126 A.3d 1266 (Pa. 2015) (interpreting phrase “legally bound” and consideration in arbitration/contract context)
Pisano v. Extendicare Homes, Inc., 77 A.3d 651 (Pa. Super. 2013) (two-part test for compelling arbitration: existence of valid agreement and scope)
Franklin Interiors v. Wall of Fame Mgmt. Co. Inc., 511 A.2d 761 (Pa. 1986) (contracts with express conditional language requiring approval/signature are not binding until that condition is met)
Shovel Transfer Storage, Inc. v. Pa. Liquor Control Bd., 739 A.2d 133 (Pa. 1999) (signatures are unnecessary unless required by law or parties’ intent)