Taylor Morrison of Texas, Inc. and Taylor Woodrow Communities-League City, Ltd. v. Michelle Ha, Individually and as Next Friend of C.M.X., Minor Child 1, A.H.X., Minor Child 2, and H.R.X., Minor Child 3, 660 S.W.3d 529

In March 2015 Tony Ha signed a purchase agreement for a new home that included a broad arbitration clause covering disputes arising from the purchase, the property, the subdivision, or related transactions.
In February 2020 Tony sued Taylor Morrison for construction defects (mold, health injuries, repair/remediation costs); his wife Michelle and their three minor children joined the suit; pleadings largely asserted factually intertwined claims across family members.
Taylor Morrison moved to compel arbitration as to all plaintiffs; the trial court compelled arbitration for Tony but denied it for Michelle and the children; the court of appeals affirmed that denial.
The Texas Supreme Court addressed whether nonsignatory family members (spouse and minor children) who lived in the purchased home may be compelled to arbitrate via direct-benefits estoppel even if they did not sign the purchase agreement or assert contract claims.
The Court held that occupancy of the family home and the integrated nature of the family’s claims establish that the nonsignatory spouse and minor children accepted direct benefits of the purchase agreement and therefore can be compelled to arbitrate with the signatory spouse.
The Supreme Court reversed the court of appeals and remanded for entry of an order consistent with compelling arbitration for Mrs. Ha and the children.

Issue	Ha's Argument	Taylor Morrison's Argument	Held
Whether nonsignatory spouse and minor children are bound to arbitrate by direct-benefits estoppel	Their claims are not based on the purchase contract, so they should not be bound	Nonsignatories accepted direct benefits of the contract and thus must arbitrate	Yes — direct-benefits estoppel applies; they may be compelled to arbitrate
Whether mere occupancy of the family home suffices to show acceptance of contract benefits	Occupancy alone is insufficient absent contract-based claims or clearer assent	Occupancy indicates acceptance of direct benefits and supports estoppel	Yes — family occupancy of the purchased home indicates acceptance of benefits and supports estoppel
Whether parents can bind minor children to arbitration via estoppel	Minors cannot be bound because they did not sign and contracts with minors are generally voidable	Parents may equitably bind children by seeking direct benefits for them from the contract or by suing on their behalf	Yes — parents can equitably bind children via direct-benefits estoppel in this context
Whether the trial court erred by not holding an evidentiary hearing after the amended petition	(Ha) Not addressed on the merits	(Taylor Morrison) Hearing required before ruling	Not reached (Court resolved case on direct-benefits-estoppel grounds)

In re Weekley Homes, L.P., 180 S.W.3d 127 (Tex. 2005) (recognizes nonsignatory binding doctrines and that direct-benefits estoppel can rest on obtaining contract benefits outside litigation)
Jody James Farms, JV v. Altman Grp., Inc., 547 S.W.3d 624 (Tex. 2018) (discusses methods for binding nonsignatories to arbitration clauses)
In re Kellogg Brown & Root, Inc., 166 S.W.3d 732 (Tex. 2005) (explains direct-benefits estoppel: nonsignatory seeking contract benefits cannot avoid arbitration burdens)
In re FirstMerit Bank, N.A., 52 S.W.3d 749 (Tex. 2001) (applies estoppel to nonsignatory occupants who made no distinction between claims of signatories and nonsignatories)
Rachal v. Reitz, 403 S.W.3d 840 (Tex. 2013) (reinforces that occupancy and planned ownership indicate acceptance of contract benefits)
Laster v. First Huntsville Props. Co., 826 S.W.2d 125 (Tex. 1991) (spousal homestead rights can create vested interests independent of title)
Tenet Hosps. Ltd. v. Rivera, 445 S.W.3d 698 (Tex. 2014) (parents presumed to act in children’s best interests; parents may make significant legal decisions for children)
In re Ford Motor Co., 220 S.W.3d 21 (Tex. App.—San Antonio 2006) (recognizes parents may equitably bind children to arbitration through direct-benefits estoppel)
United States v. Rodgers, 461 U.S. 677 (1983) (discusses homestead protections and spouse consent requirements)