ST. LOUIS — In a decision issued by the Missouri Court of Appeals Eastern District, the appellate court has affirmed in part and reversed in part a lower court’s denial of a motion to compel arbitration filed by AutoCenters Bonne Terre and its representative.
The case stems from a legal dispute initiated by plaintiff Ashley Dill over a vehicle purchase in April 2023, which she alleges involved violations of the Missouri Merchandising Practices Act, breach of contract, unjust enrichment and fraud, according to the decision filed June 3 in Missouri Court of Appeals Eastern District.
The core of the appeal focused on whether Dill was bound by an arbitration agreement she signed during the vehicle purchase. Dill signed the arbitration agreement and an installment contract on April 12, 2023, at the time of the transaction.
Although the arbitration agreement bore only Dill’s signature and not that of AutoCenters, the appellate court determined that the lack of a company signature did not render the agreement unenforceable.
In reversing the trial court’s ruling as to AutoCenters Bonne Terre, the Court of Appeals concluded that sufficient consideration supported the arbitration agreement when it was construed alongside the installment contract.
Citing Missouri law, the appellate panel emphasized that contracts signed simultaneously and relating to the same transaction should be interpreted together. Because Dill acknowledged signing a large number of documents during the purchase and both key agreements bore the same date, the court held they should be read in conjunction.
The trial court had initially ruled the arbitration agreement lacked “a recital of separate consideration to independently support itself” and was unenforceable because it was only signed by Dill. The appeals court rejected this reasoning, pointing to established precedent that consideration for arbitration can be part of the broader transaction.
The court noted that Dill received a vehicle in exchange for her promises to pay and to arbitrate most claims, which was sufficient to support the agreement as a whole.
Furthermore, the appellate judges disagreed with the trial court’s conclusion that the lack of AutoCenters' signature voided the arbitration agreement.
The court clarified that the party seeking to enforce an arbitration agreement—here, AutoCenters—need not have signed it, particularly when the related installment contract bore multiple signatures from AutoCenters’ representatives.
Additionally, the court found that AutoCenters retained its rights under the arbitration clause even after assigning the installment contract to a third party.
The language of the arbitration agreement explicitly extended to successors and assigns, thereby preserving AutoCenters’ right to enforce it.
However, the appeals court did affirm the trial court’s ruling regarding Jason Hale, who is AutoCenter’s representative in the case. The trial court had found the arbitration agreement unenforceable as to Hale on the basis that he was not a party to the agreement. On appeal, Hale did not challenge this finding.
As a result, the appellate court found no error in the trial court’s decision and upheld that portion of the judgment.
The case has been remanded to the trial court for further proceedings consistent with this ruling. The opinion was authored by Judge Robert M. Clayton III, with Presiding Judge John P. Torbitzky and Judge Michael S. Wright concurring.
Lori R. Koch is reprsenting the appellant.
Joanthan E. Skrabacz is representing the respondent.
Missouri Court of Appeals Eastern District case number: ED113090
