State ex rel. Regional Convention v. Burton, 533 S.W.3d 223

The Regional Convention and Sports Complex Authority (Authority) leased a training facility to the St. Louis Rams, LLC (Rams) and later sued to void lease provisions giving the Rams a $1 purchase option.
The Authority filed a three-count declaratory-judgment petition seeking relief under the lease.
The Rams moved to compel arbitration under a broad arbitration clause in paragraph 45 of Schedule I of the lease (covering “all disputes between the Parties hereto arising out of this Lease”).
The Authority sought a stay of arbitration, arguing the lease’s attorney-fee, litigation-location, and “judgment” language show the parties intended declaratory-judgment claims to be decided in court.
The circuit court compelled arbitration and dismissed the suit; the court of appeals issued a preliminary writ of mandamus to stay arbitration and later made it permanent; the Missouri Supreme Court granted transfer and quashed the preliminary writ.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the declaratory-judgment action is subject to the lease’s arbitration clause	Authority: other lease provisions (attorney-fee "judgment" language, rights to "institute suit," forum-selection/litigation clauses) show intent to exclude declaratory relief from arbitration	Rams: arbitration clause is broad and covers any dispute arising out of the lease, including declaratory claims	The arbitration clause is broad; the other provisions do not unambiguously exclude declaratory actions, so arbitration applies
Whether the arbitration agreement lacks consideration and is unenforceable	Authority: arbitration clause unsupported by consideration	Rams: the contract as a whole supplies consideration, so no separate consideration for arbitration is needed	Consideration argument rejected; arbitration clause enforceable as part of the contract as a whole

State ex rel. Hewitt v. Kerr, 461 S.W.3d 798 (Mo. banc 2015) (mandamus appropriate to review erroneously granted motion to compel arbitration)
Eaton v. CMH Homes, 461 S.W.3d 426 (Mo. banc 2015) (de novo review of whether court should have compelled arbitration; arbitration-clause consideration principles)
Dunn Indus. Grp., Inc. v. City of Sugar Creek, 112 S.W.3d 421 (Mo. banc 2003) (liberal federal policy favoring arbitration; ambiguous questions resolved for arbitration; language excluding claims must be unmistakably clear)
United Steelworkers of Am. v. Warrior & Gulf Navigation Co., 363 U.S. 574 (U.S. 1960) (broad arbitration clauses cover disputes absent clear exclusion)
Baker v. Bristol Care, Inc., 450 S.W.3d 770 (Mo. banc 2014) (definition of consideration for contract enforcement)