Sutton v. David Stanley Chevrolet, Inc.

Sutton, 2020 OK 87 (Okla. 2020) · Supreme Court of Oklahoma · October 13, 2020 · No. No. 117587; Comp. w/117588

Summary

The Oklahoma Supreme Court reviewed a motion to compel arbitration arising from a vehicle purchase dispute. It held that the trial court's finding of constructive fraud in the inducement was supported by the evidence, vacated the Court of Civil Appeals' opinion, affirmed the trial court's order, and remanded for further proceedings.

Holdings

  1. The district court's order overruling the motion to compel arbitration was supported by the evidence because the circumstances established constructive fraud concerning the arbitration clause.
  2. Under the specific circumstances, the finance manager had a duty to disclose the material dispute resolution clause because the manager's representations and the structure of the purchase agreement created a false impression about what Sutton was signing.
  3. Sutton's failure to read the finely printed dispute resolution clause was not a defense to his constructive-fraud claim where the dealership's conduct created a false impression about the provision and induced his signature.

Questions Presented

  1. Whether Sutton presented sufficient evidence of constructive fraud or fraudulent inducement to defeat the dealership's motion to compel arbitration.
  2. Whether the dealership's finance manager had a duty to disclose the dispute resolution clause when the manager partially explained the purchase agreement and the agreement's structure created a false impression about the purpose of Sutton's signature.
  3. Whether Sutton's failure to read the dispute resolution clause barred his constructive-fraud challenge.

Disposition

vacated

Cases Cited (27)

  • Rogers v. Dell Computer Corp., 2005 OK 51, 138 P.3d 826(followed)
  • Hill v. Blevins, 2005 OK 11, 109 P.3d 332(followed)
  • Signature Leasing LLC v. Buyer's Group LLC, 2020 OK 50, 466 P.3d 544(followed)
  • Prima Paint Corp. v. Flood & Conklin Manufacturing Co., 388 U.S. 395, 403-404 (1967)(followed)
  • Patel v. OMH Medical Center, Inc., 1999 OK 33, 987 P.2d 1185(followed)
  • Croslin v. Enerlex, Inc., 2013 OK 34, 308 P.3d 1041(followed)
  • Deardorf v. Rosenbusch, 1949 OK 117, 206 P.2d 996(followed)
  • Berry v. Stevens, 1934 OK 167, 31 P.2d 950(followed)
  • Barry v. Orahood, 1942 OK 419, 132 P.2d 645(followed)
  • Morris v. McLendon, 1933 OK 619, 27 P.2d 811(followed)

Showing top 10 of 27.

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