By: Derek Hawkins//January 31, 2018//
7th Circuit Court of Appeals
Case Name: Matthew Warciak v. Subway Restaurants, Inc.
Case No.: 17-1956
Officials: KANNE and SYKES, Circuit Judges, and DARROW, District Judge
Focus: Contract Arbitration Clause
Should courts apply federal or state law to decide whether a contract’s arbitration clause binds a non-signatory? In Scheurer v. Fromm Family Foods LLC, we held that courts should apply state law. 863 F.3d 748, 750 (7th Cir. 2017). We reiterate that holding here. Subway sought to enforce against Warciak an arbitration agreement that neither party had signed. Because Illinois promissory estoppel does not bind Warciak to the arbitration agreements between T-Mobile and his mother, we REVERSE the district court’s order dismissing Warciak’s suit and compelling arbitration and REMAND for further proceedings.
Reversed and Remanded