Neal v. Navient Solutions, LLC, No. 19-2775 (8th Cir. 2020)
Annotate this CaseOhio law allows nonsignatory agents to compel arbitration under general principles of contract and agency law. The Eighth Circuit reversed the district court's denial of Navient's motion to compel arbitration against plaintiff. The court disagreed with the district court's finding that the relevant arbitration clause does not include Navient as a party and so Navient cannot compel arbitration. Rather, the court held that Ohio law permits plaintiff to compel arbitration as a nonsignatory agent of the holder of the loan. The court also held that Ohio's rule of alternate estoppel prevents plaintiff from disavowing the arbitration clause because his claim arises out of the same contract. Therefore, plaintiff is estopped from avoiding the arbitration clause because his claims are integrally intertwined with the contract containing the agreement to arbitrate. Accordingly, the court remanded for further proceedings.
Court Description: [Kobes, Author, with Smith, Chief Judge, and Benton, Circuit Judge] Civil case - Arbitration. The Ohio law applicable to the case allows nonsignatory agents to compel arbitration under general principles of contract and agency law, and the district court erred in finding that Navient,the nonsignatory agent of the holder of the loan, could not compel arbitration; further, Neal is estopped from avoiding the arbitration clause because his claims are integrally intertwined with the contract containing the agreement to arbitrate.
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