Kiara Standifer and Quentina Tate v. Suntrup Hyundai, Inc. and Hyundai Motor America Corp.

CourtMissouri Court of Appeals
DecidedAugust 6, 2024
DocketED112162
StatusPublished

This text of Kiara Standifer and Quentina Tate v. Suntrup Hyundai, Inc. and Hyundai Motor America Corp. (Kiara Standifer and Quentina Tate v. Suntrup Hyundai, Inc. and Hyundai Motor America Corp.) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kiara Standifer and Quentina Tate v. Suntrup Hyundai, Inc. and Hyundai Motor America Corp., (Mo. Ct. App. 2024).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION FOUR

KIARA STANDIFER and ) No. ED112162 QUENTINA TATE, ) ) Respondents, ) Appeal from the Circuit Court of ) St. Louis County v. ) Cause No. 23SL-CC02853 ) SUNTRUP HYUNDAI, INC. and ) HYUNDAI MOTOR AMERICA CORP., ) Honorable John N. Borbonus ) Appellants. ) Filed: August 6, 2024

Suntrup Hyundai, Inc. and Hyundai Motor America Corp. (collectively, “Suntrup”)

appeal the circuit court’s order overruling its motion to compel arbitration of two consumer

disputes. Suntrup alleged there were valid, binding arbitration agreements requiring arbitration

rather than resolution by the circuit court.

Because the consumers’ arbitration agreements are enforceable and the consumers failed

to submit their claims to arbitration, the circuit court’s judgment denying Suntrup’s motion to

compel arbitration is vacated. This case is remanded to the circuit court with instructions to issue

an order compelling arbitration. Background

Kiara Standifer and Quentina Tate (collectively, “Consumers”) each purchased a

Hyundai vehicle from a dealership in St. Louis County. Subsequent to their purchases,

Consumers’ vehicles were stolen.

Consumers filed a petition in the circuit court, claiming Suntrup violated the Missouri

Merchandising Practices Act, section 407.010 et seq., RSMo 2016, 1 because Suntrup failed to

install the appropriate anti-theft protection devices in their vehicles. Suntrup timely moved to

compel arbitration and stay the proceedings because Consumers signed arbitration agreements

requiring arbitration of all disputes.

Consumers conceded they signed arbitration agreements but claimed they were relieved

of their obligation to arbitrate because Suntrup failed to register the arbitration agreements with

the American Arbitration Association (“AAA”) as required by AAA rules. Accordingly,

Consumers argued they were not required to submit their claims to arbitration and could proceed

in the circuit court. Suntrup replied, asserting Consumers’ arbitration agreements allowed for a

choice of arbitrators, it had registered with the AAA, and any determination regarding

arbitrability of a different state case in the circuit court is not binding in this case. See Martin v.

HW Automotive, LLC, No. ED112165, --- S.W.3d --- (Mo. App. August 6, 2024).

The circuit court held a hearing on the motion to compel and entered a judgment denying

Suntrup’s motion to compel arbitration. Suntrup appeals pursuant to § 435.440.1(1).

Standard of Review

Section 435.355 governs the procedure for resolving a motion to compel arbitration. If

the party seeking to compel arbitration demonstrates there is a valid arbitration agreement and

1 All statutory references are to RSMo 2016. 2 the party opposing the motion refuses to arbitrate, “the court shall order the parties to proceed

with arbitration ….” Section 435.355.1. If the party opposing the motion denies the existence of

an arbitration agreement, then “the court shall proceed summarily to the determination of the

issue so raised and shall order arbitration if found for the moving party ….” Id. In “an appeal

from a circuit court’s order overruling a motion to compel arbitration when there is a dispute as

to whether the arbitration agreement exists, the circuit court’s judgment will be affirmed unless

there is no substantial evidence to support it, it is against the weight of the evidence, or it

erroneously declares or applies the law.” Theroff v. Dollar Tree Stores, Inc., 591 S.W.3d 432,

436 (Mo. banc 2020).

However, when there is no dispute about the existence of an arbitration agreement, this

Court conducts de novo review of whether a motion to compel arbitration should be sustained.

Bridgecrest Acceptance Corp. v. Donaldson, 648 S.W.3d 745, 751 (Mo. banc 2022). This Court

also engages in de novo review to determine “whether the right to insist on arbitration, if present,

has been waived.” GFS, II, LLC v. Carson, 684 S.W.3d 170, 176 (Mo. App. 2023) (quoting Frye

v. Speedway Chevrolet Cadillac, 321 S.W.3d 429, 435 (Mo. App. 2010). When a reviewing court

engages in de novo review, it “exercises independent judgment to correct erroneous

interpretations.” Missouri Pub. Serv. Comm’n v. Union Elec. Co., 552 S.W.3d 532, 539 (Mo.

banc 2018) (internal quotation omitted). The circuit court’s decision is given no deference in de

novo review. Chastain v. United Fire & Cas. Co., 653 S.W.3d 616, 620 (Mo. App. 2022).

Because Consumers concede they signed arbitration agreements with Suntrup, this Court’s

review of the order overruling Suntrup’s motion to compel is de novo.

3 Analysis

“[A]rbitration is a matter of contract.” Rent-A-Ctr., W., Inc. v. Jackson, 561 U.S. 63, 67,

130 S. Ct. 2772, 177 L.Ed.2d 403 (2010). “The usual rules and canons of contract interpretation

govern the subsistence and validity of an arbitration clause.” Dunn Indus. Grp., Inc. v. City of

Sugar Creek, 112 S.W.3d 421, 428 (Mo. banc 2003); see also Am. Exp. Co. v. Italian Colors

Rest., 570 U.S. 228, 233, 133 S. Ct. 2304, 2309, 186 L. Ed. 2d 417 (2013); Bridgecrest, 648

S.W.3d at 752 (applying contract principles to an arbitration dispute).

Consumers do not dispute that their claims are subject to a binding arbitration agreement.

Instead, Consumers assert they are relieved of their obligation to arbitrate because the circuit

court in a different case, Martin v. H.W. Automotive LLC, did not compel arbitration after finding

that the Martin defendants failed to properly register their arbitration clause with the AAA.

Consumers suggest that, because the AAA declined to arbitrate the claims in Martin, this Court

should assume that the AAA would also decline to arbitrate Consumers’ claims here.

Consumers’ argument that this Court should rely on a circuit court’s order in another case

involving different parties is incorrect. This Court evaluates each case on its own merits, and in

this case, Consumers agree that they have signed a binding arbitration clause. Although Martin

involved similar claims to those at issue here, it dealt with different parties and different

arbitration clauses. Martin also involved evidence that the plaintiffs in that case actually

attempted to initiate an arbitration.

The record in this case lacks any support for Consumers’ argument that an arbitrator

would refuse to accept their cases for arbitration. Consumers have not presented any evidence

that they attempted to arbitrate their claims or that their claims would be rejected if they

4 attempted to do so. As a result, the circuit court erred in failing to compel the parties to arbitrate

based only on a similar refusal in a separate case. 2

Additionally, Consumers argue this Court should affirm the circuit court’s judgment

because Suntrup waived arbitration by responding to Consumers’ lawsuit. 3 A court may

determine whether a party waives its right to compel arbitration when that party affirmatively

litigated the dispute in the circuit court. Carson, 684 S.W.3d at 178. “A claim that a litigant has

Free access — add to your briefcase to read the full text and ask questions with AI

Related

American Express Co. v. Italian Colors Restaurant
133 S. Ct. 2304 (Supreme Court, 2013)
Dunn Industrial Group, Inc. v. City of Sugar Creek
112 S.W.3d 421 (Supreme Court of Missouri, 2003)
Boulds v. Dick Dean Economy Cars, Inc.
300 S.W.3d 614 (Missouri Court of Appeals, 2010)
Frye v. Speedway Chevrolet Cadillac
321 S.W.3d 429 (Missouri Court of Appeals, 2010)
Mo. Pub. Serv. Comm'n v. Union Elec. Co.
552 S.W.3d 532 (Supreme Court of Missouri, 2018)
Morgan v. Sundance, Inc.
596 U.S. 411 (Supreme Court, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
Kiara Standifer and Quentina Tate v. Suntrup Hyundai, Inc. and Hyundai Motor America Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/kiara-standifer-and-quentina-tate-v-suntrup-hyundai-inc-and-hyundai-moctapp-2024.