Warciak v. Subway Restaurants, Inc.

Dist. Ct. erred in granting defendant’s motion to compel arbitration of plaintiff’s claim that defendant had wrongfully sent spam text message to plaintiff’s cell-phone, where said motion was based on arbitration clause contained in cell-phone agreement between T-Mobile and plaintiff’s mother. Generally, court cannot compel party to arbitrate dispute unless said party has agreed to do so, and while Dist. Ct. applied federal law to grant motion to compel arbitration, it should have applied state promissory estoppel principles to decide whether non-party to contract should be bound by terms of another person’s contract. Moreover, under Illinois law, defendant could not rely on estoppel principles to enforce T-Mobile’s arbitration clause against plaintiff, because defendant cannot show any detrimental reliance on statements or conduct of plaintiff.