Dickson v. Gospel for ASIA, Inc., No. 17-1191 (8th Cir. 2018)Annotate this Case
Plaintiffs filed suit against GFA, alleging that GFA solicited charitable donations to benefit the poorest of the poor while covertly diverting the money to a multi-million dollar personal empire. The district court denied GFA's motion to compel arbitration.
The Eighth Circuit held that the district court interpreted the scope of the arbitration agreements too narrowly, reasoning that, since none of the mission statements or pledges found in the agreements reach donations made to the church, the dispute was entirely unrelated to the parties' agreements. The court held that, even if the agreements did not reach donations made to GFA, the district court erred because the arbitration agreements did not apply only to disputes arising out of the agreements. Rather, they applied by their terms to any and all disputes of any kind arising out of the relationship between plaintiffs and GFA. Because the court could not say with positive assurance that the donations plaintiffs made to GFA did not arise out of that relationship, the court reversed and remanded.