Spring Lake NC, LLC v. Holloway, 110 So. 3d 916

Ms. Holloway, 92, signed a standard admission/financial agreement and a separate arbitration agreement upon entering Spring Lake rehabilitation center.
She had limited reading ability, memory problems, and confusion, but no evidence showed staff coercion or misrepresentation in obtaining her signature.
The trial court declined to enforce the arbitration clause, finding no meeting of minds due to her purported inability to understand the contracts.
The court acknowledged Florida authority that signing parties are generally bound unless prevented from reading or induced not to read, but found the agreements too complex for Holloway to comprehend.
This Court held that her limited abilities do not negate enforceability of the contract, and reversed the decision, remanding for arbitration enforcement, while discussing a shift from “meeting of the minds” to mutual assent in modern contract analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the arbitration clause is enforceable against Holloway despite her limited reading ability	Spring Lake argues Holloway is bound; signing and acceptance create a binding contract	Holloway's limited understanding rendered no true meeting of minds	Enforceable; reversed and remanded for arbitration

D.L. Peoples Group, Inc. v. Hawley, 804 So.2d 561 (Fla. 1st DCA 2002) (presumption of competence; binding contract when signed and accepted)
Skinner v. Haugseth, 426 So.2d 1127 (Fla. 2d DCA 1983) (signing party bound unless prevented from reading or induced not to read)
Mandell v. Fortenberry, 290 So.2d 3 (Fla.1974) (parties signing legal documents presumed competent; bound by covenants)
Dodge of Winter Park, Inc. v. Morley, 756 So.2d 1085 (Fla. 5th DCA 2000) (generally enough that the party against whom enforcement is sought signs)
Consol. Res. Healthcare Fund I, Ltd. v. Fenelus, 853 So.2d 500 (Fla. 4th DCA 2003) (not reading or being prevented from reading can still bind signer)
Allied Van Lines, Inc. v. Bratton, 351 So.2d 344 (Fla. 1977) (contract binding absent evidence of prevention or inducement)
Estate of Etting ex rel. Etting v. Regents Park at Aventura, Inc., 891 So.2d 558 (Fla. 3d DCA 2004) (legally blind signer not invalidating arbitration absent coercion or lack of contents)
Rocky Creek Retirement Props., Inc. v. Estate of Fox ex rel. Bank of Am., N.A., 19 So.3d 1105 (Fla. 2d DCA 2009) (alleged inability to understand does not vitiate assent)
SA-PG Sun City Ctr., LLC v. Kennedy, 79 So.3d 916 (Fla. 2d DCA 2012) (mutuality of assent affirmed as objective concept)