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A federal district court in Alabama ordered a nonsignatory to arbitrate his claims because his claims were "interwined with, indistinguishable from, and dependent upon" a signatory's claims.
In Spurlock v. Green Tree-Al, LLC, No. 306-CV-1026-MEF, 2006 WL 3834278 (M.D. Ala. Dec. 22, 2006), Brenda Spurlock financed a home through Green Tree. In connection with that transaction, the parties executed an arbitration agreement.
When Brenda and her husband John sued Green Tree for alleged harassment in its collection efforts, Green Tree filed a motion to compel arbitration. The Spurlocks filed no response. The only issue before the Court was whether John had to arbitrate his claims even though he was not a party to the arbitration agreement.
The Court concluded that John had to submit his claims to arbitration under the doctrine of equitable estoppel because his claims were "intertwined with, indistinguishable from, and dependent upon" Brenda's claims. Accordingly, the Court ordered the parties to submit all claims to arbitration.
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