UBS Financial Services, Inc. v. Catherine Meo Saunders; Joseph A. Meo, individually and as co-trustee of the Robert and Agnes Meo Trust fbo Catherine Saunders; and Richard Schutt

No. 2D2024-2958 · District Court of Appeal of Florida, Second District · November 19, 2025 · No. 2D2024-2958

Summary

The Florida Second District Court of Appeal reversed an order denying UBS Financial Services' motion to compel arbitration. The court held that Catherine Meo Saunders, although she did not sign the account agreement, was equitably estopped from disclaiming its arbitration provision because her claims sought direct benefits under that agreement. The case was remanded for arbitration.

Holdings

  1. A nonsignatory who expressly seeks benefits and contractual services under an agreement may be equitably estopped from disclaiming the agreement's arbitration provision.
  2. The trial court erred by denying UBS's motion to compel arbitration; the court should have estopped Saunders from disclaiming the arbitration provision and compelled arbitration.

Questions Presented

  1. Whether a nonsignatory co-trustee who sues to obtain benefits and contractual account services under an agreement is equitably estopped from avoiding that agreement's arbitration provision.
  2. Whether the trial court erred in denying UBS's motion to compel arbitration.

Disposition

reversed_and_remanded

Cases Cited (15)

  • Venn Therapeutics, LLC v. CAC Pharma Invs., LLC, 382 So. 3d 6, 11 (Fla. 2d DCA 2024)(followed)
  • Addit, LLC v. Hengesbach, 341 So. 3d 362, 366 (Fla. 2d DCA 2022)(followed)
  • Jackson v. Shakespeare Found., Inc., 108 So. 3d 587, 593 (Fla. 2013)(followed)
  • Patricia Seifert v. U.S. Home Corporation, et al., Seifert v. U.S. Home Corp., 750 So. 2d 633, 636 (Fla. 1999)(followed)
  • Qubty v. Nagda, 817 So. 2d 952, 956 (Fla. 5th DCA 2002)(followed)
  • Integrated Health Servs. at Cent. Fla., Inc. v. Est. of DeSantis, 407 So. 3d 547, 551 (Fla. 2d DCA 2025)(followed)
  • Pezeshkan v. Manhattan Constr. Fla., Inc., 313 So. 3d 948, 951 (Fla. 2d DCA 2021)(followed)
  • Stalley v. Transitional Hosps. Corp. of Tampa, Inc., 44 So. 3d 627, 629, 632 (Fla. 2d DCA 2010)(followed)
  • Allied Pros. Ins. v. Fitzpatrick, 169 So. 3d 138, 142 (Fla. 4th DCA 2015)(followed)
  • Johnson v. Pires, 968 So. 2d 700, 701 (Fla. 4th DCA 2007)(followed)

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