JEFFERSON CITY — The Missouri Supreme Court has ruled that a negligence dispute involving UATP Springfield, which is doing business as Urban Air Springfield, must proceed to arbitration, overturning a lower court's decision.
The court's opinion, issued on March 4, vacates the Greene Circuit Court's denial of Urban Air's motion to compel arbitration. The Supreme Court determined that because the arbitration agreement signed on Presley Karlin's behalf includes a delegation clause, an arbitrator—not the courts—must decide whether the agreement applies to Karlin's claims.
The case stems from a March 28, 2021, incident when 17-year-old Karlin was injured at Urban Air, an interactive trampoline and adventure park in Springfield, Missouri.
Karlin alleges that Urban Air's negligence caused his injuries by providing inadequate protective cushions and failing to address a dangerous condition. After turning 18, Karlin filed a lawsuit against Urban Air.
Urban Air sought to dismiss the lawsuit or compel arbitration, relying on four Release and Indemnification Agreements signed by adults on Karlin's behalf.
On appeal, Urban Air focused on a release signed by Karlin's mother on Nov. 14, 2020, four months before his injury.
Karlin contested the arbitration agreement on two grounds: first, that his mother lacked the legal authority to bind him to arbitration, and second, that the agreement only applied to claims arising on the day it was signed.
The Supreme Court, however, ruled that these challenges concern the validity and scope of the agreement and, under the delegation clause, must be decided by the arbitrator.
"Any dispute or claim arising out of or relating to the scope, arbitrability, or validity of this arbitration agreement... shall be settled by binding arbitration," the opinion states, citing the agreement's language.
The court noted that since Karlin did not raise a challenge specific to the delegation clause itself, the matter must proceed to arbitration.
In its analysis, the court distinguished Karlin's case from previous rulings, including Theroff v. Dollar Tree Stores, Inc., which addressed whether an agreement existed at all.
Unlike Theroff, where the injured party never knowingly consented to arbitration, Karlin acknowledged that his mother signed the agreement on his behalf.
The opinion stated that this placed his claims within the legal questions of the agreement's validity and scope, which the arbitrator is empowered to resolve.
The court also clarified the legal framework governing motions to compel arbitration.
If a factual dispute exists regarding the existence of an arbitration agreement, the circuit court must resolve it.
However, if the agreement includes a valid delegation clause, courts must enforce it unless a party raises a specific challenge to the clause itself. Since Karlin did not offer such a challenge, the delegation clause is enforceable.
As a result of the ruling, the Supreme Court vacated the circuit court's decision and remanded the case with instructions to grant Urban Air's motion to compel arbitration.
This means that Karlin's negligence claims will be decided through arbitration rather than a public court proceeding.
Urban Air was represented by J. Taylor White of Kutak Rock LLP in Springfield and Michael L. Amaro of Amaro Baldwin LLP in Long Beach, Calif.
Karlin was represented by Brandon C. Potter and Daniel P. Molloy of Aaron Sachs & Associates PC in Springfield.
The attorneys declined to comment on the case.
Missouri Supreme Court case number: SC100512