Motion for Arbitration-Minor

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7^th Circuit Court of Appeals

Case Name: Alex Coatney v. Ancestry.com DNA, LLC

Case No.: 22-2813

Officials: Flaum, Easterbrook, and Brennan, Circuit Judges.

Focus: Motion for Arbitration-Minor

Minor plaintiffs had their guardians purchase and activate DNA test kits from Ancestry.com. Through their guardians, the plaintiffs provided DNA samples to Ancestry.com for genetic analysis. Subsequently, they sued Ancestry.com, alleging that the company breached their privacy rights by sharing their confidential genetic data with another entity. Ancestry.com sought to enforce arbitration, citing a clause in its Terms & Conditions agreement, which the plaintiffs’ guardians had accepted when buying and activating the test kits.

The Seventh Circuit, applying Illinois law, ruled that the plaintiffs were not obligated to arbitrate their claims under the agreement between their guardians and Ancestry.com. The court reasoned that the plaintiffs hadn’t signed the agreement, hadn’t created Ancestry.com accounts, and hadn’t independently utilized Ancestry.com’s services. Additionally, the court declined to enforce the agreement on equitable grounds, such as the doctrine of direct benefits estoppel. Notably, while the plaintiffs theoretically could have benefited from Ancestry.com’s services, there was no evidence that they had accessed their DNA test results.

The court upheld the district court’s decision to deny Ancestry.com’s motion for arbitration. This ruling clarified that under Illinois law, a minor cannot be bound by an arbitration agreement their guardian accepted on their behalf, unless the minor independently engaged with the services outlined in the agreement or directly reaped benefits from it.

Affirmed.

Decided 02/15/24

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