Summary
The United States District Court for the Middle District of Pennsylvania adopted a magistrate judge’s report and recommendation and addressed Motorworld Automotive Group, Inc.’s motion to dismiss Norris Hammond’s amended complaint. The court held that the parties agreed to arbitrate disputes under an arbitration clause in Hammond’s credit application, including disputes concerning arbitrability. The court compelled arbitration, stayed the case pending arbitration, administratively closed the case, and denied the remaining motions as moot.
Holdings
- The credit application contained a clear and enforceable arbitration clause stating that disputes arising from or relating to the application or any resulting transaction or relationship would be resolved by binding arbitration rather than court action.
- Motorworld manifested mutual assent to the arbitration agreement through its conduct, including submitting the application to potential lenders, despite the absence of its signature.
- The application created a bilateral agreement because Hammond and Motorworld each made a promise supported by consideration.
- The arbitration clause contained an unambiguous delegation provision assigning disputes over the interpretation, scope, validity, and arbitrability of the application and arbitration agreement to the arbitrator.
- Motorworld's motion to dismiss the amended complaint was granted, all claims were compelled to arbitration, and the action was stayed pending arbitration.
Questions Presented
- Whether the signed credit application contained a valid arbitration agreement.
- Whether Motorworld assented to the arbitration agreement despite not signing the application.
- Whether the arbitration clause constituted a bilateral agreement supported by reciprocal promises.
- Whether the arbitration clause delegated questions concerning the interpretation, validity, scope, and arbitrability of the agreement to the arbitrator.
- Whether the amended complaint should be dismissed and the parties compelled to arbitrate all claims.
Disposition
other
Cases Cited (28)
- Golden Gate Nat'l Senior Care, LLC v. Sulpizio, No. 1:15-CV-0174, 2016 WL 1271333, at *2 (M.D. Pa. Mar. 31, 2016)(followed)
- Century Indem. Co. v. Certain Underwriters at Lloyd's London, 584 F.3d 513, 522 (3d Cir. 2009)(followed)
- Bel-Ray Co. v. Chemrite (Pty) Ltd., 181 F.3d 435, 444 (3d Cir. 1999)(followed)
- Flintkote Co. v. Aviva PLC, 769 F.3d 215, 220 (3d Cir. 2014)(followed)
- Harris v. Green Tree Fin. Corp., 183 F.3d 173, 179 (3d Cir. 1999)(followed)
- Moses H. Cone Mem'l Hosp. v. Mercury Constr. Corp., 460 U.S. 1, 25 n.32 (1983)(followed)
- Doctor's Associates, Inc. v. Casarotto, 517 U.S. 681, 687 (1996)(followed)
- Perry v. Thomas, 482 U.S. 483, 492 (1987)(followed)
- Guidotti v. Legal Helpers Debt Resolution, LLC, 716 F.3d 764, 773-76 (3d Cir. 2013)(followed)
- Somerset Consulting, LLC v. United Capital Lenders, LLC, 832 F. Supp. 2d 474, 479, 482 (E.D. Pa. 2011)(followed)
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Court Document
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